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Archived: Polmedics Limited - Wellingborough

Reports


Inspection carried out on 10 February 2017

During an inspection to make sure that the improvements required had been made

We carried out an unannounced focused inspection on 10 February 2017 of Polmedics Limited - Wellingborough. We carried out this inspection because the provider confirmed to the Commission that this location re-commenced the provision of dental services only to patients as from 7 February 2017 following previous actions taken by the provider to voluntarily suspend all services on 19 December 2016 provided across all Polmedics Ltd locations until 31 January 2017 including Polmedics Limited – Wellingbrough. The provider had taken this course of action following serious concerns raised following a series of inspections carried out at Polmedics Limited - Allison Street, Birmingham on 9 & 30 November 2016, Polmedics Limited - West Bromwich on 16 December 2016 and Polmedics Limited - Rugby on 17 December 2016 identifying serious concerns linked to the provider’s lack of governance and infrastructure arrangements.

This inspection was carried out at the same time as an announced inspection of Polmedics Ltd (the provider) at their administrative head office located at 36 Regent Place, Rugby CV21 2PN to assess their governance, infrastructure and leadership arrangements. During the inspection which had taken place at the administrative head office, we were informed by the provider that Polmedics Limited – Wellingborough was closed to patients on 10 February 2017. However, we found evidence that this location was open to patients from midday and patient appointments had been pre-booked for the day of our inspection. We therefore commenced our inspection from midday

Our findings were:

Are services safe?

We found that this service was not providing safe care in accordance with the relevant regulations.

Are services well-led?

We found that this service was not providing well-led care in accordance with the relevant regulations.

Background

Polmedics Limited – Wellingborough is an independent provider of dental and gynaecology services. The practice is located within the town centre of Wellingborough, Northamptonshire. Services are provided primarily to polish patients who reside in the United Kingdom (UK). Services are available to people on a pre-bookable appointment basis. At the time of our inspection, the provider had voluntarily suspended all services with the exception of dentistry as a result of concerns found during previous inspections carried out by the Commission at three other locations during November and December 2016.

This inspection focused solely upon the dental services provided by the clinic. On the day that we visited we found these were the only services being offered.

The practice is situated in a converted Victorian property. On the ground floor there is a waiting room with a reception area, the main dental treatment room and a decontamination room. In the basement there is a staff room, and storage areas. On the first floor of the property are the second dental treatment room as well as a consulting room and a gynaecology treatment room. Toilets for staff and patients are located on the first floor.

The practice is registered with the Care Quality Commission to provide the regulated activities of; the treatment of disease, disorder and injury; diagnostic and screening procedures; family planning, maternity and midwifery services and surgical procedures.

The practice holds a list of registered patients and offers services to patients who reside in Wellingborough and surrounding areas but also to patients who live in other areas of the UK who require their services. The provider provides regulated activities from seven different locations. We were informed by the provider that there are approximately 33,000 registered patients across all Polmedics Ltd locations.

The practice does not currently have a 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 practice is run.

The provider is not required to offer an out of hours service. Patients who need emergency medical assistance out of corporate operating hours are requested to seek assistance from alternative services such as the NHS 111 telephone service or accident and emergency.

Our key findings were:

  • The practice had limited formal governance arrangements in place. Patient outcomes were hard to identify as little or no reference was made to audits or quality improvement. For example, there was no evidence of an x-ray audit being completed.
  • Arrangements to safeguard children and vulnerable adults from abuse did not reflect relevant legislation and local requirements. The practice manager was unaware who the lead was at the practice.
  • The dentist had been told in December 2016 not to take any x-rays until training was completed. However, we saw in patient records that x-rays had been taken in December 2016 and on 4 February 2017. We spoke with the practice manager who confirmed that the dentist should not be taking x-rays at present.
  • Not all risks to patients were assessed and well managed. The practice was using easy cleaning solution for metal and jewellery in the ultrasonic cleaner. There were no soil tests completed and there was no lid for the ultrasonic cleaner. Instruments were found in autoclave from the previous day that had not been processed.

  • The provider had not ensured that a registered manager was in place. It is a requirement of registration with the Care Quality Commission where regulated activities are provided to have a registered manager in place. The person that was named as the registered manager was no longer at this practice.

  • The practice did not have an effective, overarching governance framework in place to support the delivery of the strategy and good quality care. There was a lack of effective systems and processes in place for assessing and monitoring risks and the quality of the service provision.

  • The practice was only allowing patients to pay in cash for services at the time of our inspection.

  • The practice had a number of policies and procedures in place to govern activity, but some of these required updating and some policies were not reflective of current practice.

  • Information about how to complain was available and easy to understand however, the practice manager did not know who was responsible for dealing with complaints in the practice or at the head office.

  • There was no system in place to ensure that an accurate, complete and contemporaneous record was maintained for every patient.

We identified regulations that were not being met and the provider must:

  • Ensure dental care records are maintained appropriately giving due regard to guidance provided by the Faculty of General Dental Practice and the General Dental Council regarding clinical examinations and record keeping.
  • Ensure audits of radiography are undertaken at regular intervals to help improve the quality of service.
  • Ensure effective systems and processes are in place for identifying, assessing and monitoring risks and the quality of the service provision.
  • Ensure arrangements to safeguard children and vulnerable adults from abuse reflect relevant legislation and local requirements.
  • Ensure effective processes for timely reporting, recording, acting on and monitoring of significant events, incidents and near misses are in place.
  • Review complaints processes to ensure staff and patients understand the complaints system.
  • Ensure there is effective clinical leadership in place and a system of clinical supervision/mentorship for all clinical staff including trainee dental nurses.
  • Ensure that patient safety alerts such as those issued by the Medicines and Healthcare Regulatory Authority (MHRA are received by the practice, and then actioned if relevant. Put systems in place to ensure all doctors are kept up to date with national guidance and guidelines.

  • Ensure that there are appropriate systems in place to properly assess and mitigate against risks including risks associated with infection prevention and control, decontamination of dental equipment, and legionella. Review procedures to ensure compliance with the practice annual statement in relation to infection prevention control required under The Health and Social Care Act 2008: ‘Code of Practice about the prevention and control of infections and related guidance.

There were areas where the provider could make improvements and should:

  • Review processes for ensuring fees are explained to patients prior to the procedure to enable patients to make informed decisions about their care.

  • Ensure a system of appraisals is in place to ensure all members of staff receive an appraisal at least annually.
  • Ensure appropriate policies and procedures are implemented, relevant to the practice ensuring all staff are aware of and understand them.

Inspection carried out on 10 February 2017

During a routine inspection

We carried out an announced inspection on 10 February 2017 of Polmedics Ltd (the provider) at their administrative head office located at 36 Regent Place, Rugby CV21 2PN. (We were informed by the provider that all governance and management systems in place were located at this address in Rugby and not the provider address registered with the Commission which is located in Wellingborough. We obtained verbal and written consent from the provider to carry out this inspection at their administrative head office in Rugby).

At the same time, we also carried out unannounced focused inspections of Polmedics Limited – Bristol and Polmedics Limited - Wellingborough on 10 February 2017.

These inspections were carried out due to concerns raised following a series of inspections carried out at Polmedics Limited - Allison Street, Birmingham on 9 & 30 November 2016, Polmedics Limited - West Bromwich on 16 December 2016 and Polmedics Limited - Rugby on 17 December 2016 identifying serious concerns linked to the provider’s lack of governance and infrastructure arrangements.

We inspected the provider to assess their governance and leadership arrangements in respect of these concerns, therefore it was not necessary to use all key lines of enquiry.

Our findings were:

Are services safe?

We found that the provider was not providing safe care in accordance with the relevant regulations. We have told the provider to take action (see full details of this action in the Enforcement section at the end of this report).

Are services effective?

We found that the provider was not providing effective care in accordance with the relevant regulations. We have told the provider to take action (see full details of this action in the Enforcement section at the end of this report).

Are services well-led?

We found that the provider was not providing well-led care in accordance with the relevant regulations. We have told the provider to take action (see full details of this action in the Enforcement section at the end of this report).

Background

We carried out this inspection under Section 60 of the Health and Social Care Act 2008 as part of our regulatory functions. This inspection was planned to check whether the provider was meeting the legal requirements and regulations associated with the Health and Social Care Act 2008.

Polmedics Ltd was established in 2013 and is an independent provider of dental and medical services including gynaecology, sexual health screening and other services such as consultation services which includes the diagnosis and treatment of disease and prescribing of medicines. Consultation services are provided by doctors who are referred to as internists and treats both adults and children. (At the time of our inspection, the provider confirmed that all medical services had been suspended voluntarily based on concerns found during the Commission’s inspections of three other locations during November and December 2016. It was the intention of the provider to recommence the provision of medical services in the near future).

Services are provided across seven locations in Birmingham, Bristol, Ealing, Redditch, Rugby, West Bromwich and Wellingborough primarily but not restricted to Polish patients who reside in the United Kingdom (UK). Services are available to people on a pre-bookable appointment basis and we were informed during our inspection that patients book appointments by contacting a call centre located in Poland. The provider advertise a variety of other additional services on their website such as cardiology, dermatology, midwifery, psychiatry, paediatric and orthopaedic services however, we were advised prior to our inspection that these additional services are no longer provided. The range of services advertised on the providers website differs at each location. We were informed by the provider that there are approximately 33,000 registered patients across all Polmedics Ltd locations.

Polmedics Ltd (the provider) is registered with the Care Quality Commission to provide the regulated activities of diagnostic and screening procedures, family planning, maternity and midwifery services, surgical procedures and treatment of disease, disorder or injury.

The provider had not ensured that a registered manager was in place at each location. (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). At the time of our inspection, one of seven locations had a registered manager in place, registered manager applications were in progress for five locations.

We were told that the provider had made recent changes to staffing levels and confirmed that 50 members of staff were employed across all locations. The staffing structure included three directors (one director acted as company secretary and one director who is a dentist acted as medical director). We were told that recent changes had taken place within the board of directors, there were previously four directors in post however, we were verbally informed that one director was dismissed by the provider due to a referral being carried out to the General Dental Council (GDC) we were unable to see any documented evidence of the dismissal process followed during our inspection. Each director has a specific area of responsibility such as premises and maintenance management, appointments system and scheduling, IT and recruitment. The provider employed one nominated individual who carried out the role of operational manager to oversee the management of all seven locations. There is a finance and human resources department which we were informed is located on the ground floor of Polmedics - Allison Street, Birmingham consisting of four members of staff. We were informed of seven managers being in post, one at each location (some managers were still awaiting commencement of their post dependent upon either a DBS check being received or confirmation as a CQC registered manager being received). The provider also employed a number of dentists, trainee dental nurses and receptionists across all locations. Some clinicians including dentists working in the locations live in Poland and travel to England on a regular basis to carry out shifts at each location.

Our key findings were:

  • There was an ineffective, governance framework in place to support the delivery of the strategy and good quality care. There was a lack of effective systems and processes in place for identifying, assessing and monitoring risks and the quality of the service provision across all locations.
  • There was an ineffective leadership structure in place, there was a lack of suitably trained and experienced management support in place on a daily basis at each location and there was a lack of clinical leadership and oversight at both location and provider level.
  • There was no process for ensuring that the board of directors were fit and proper persons to manage the service. This is a duty required by the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. Key documentation on the recruitment of individuals was missing from personnel files.
  • The provider had not ensured that a registered manager was in place at each location. It is a requirement of registration with the Care Quality Commission where regulated activities are provided to have a registered manager in place.
  • There was a lack of identification of risks and ineffective risk management processes in place at location and provider level to mitigate these through effective risk registers or appropriate discussion and acknowledgement of risk where highlighted by internal staff.
  • The professional registration of clinical staff working at all locations were not all routinely checked at employment. The provider did not ensure that a system was in place within the organisation to ensure professional registration was routinely checked on an ongoing basis.
  • The provider did not have an effective system or process within the organisation to ensure appropriate checks of current medical indemnity insurance had been carried out on all clinicians upon commencement of employment.
  • There was not effective governance or monitoring processes in place to ensure that children and young people were safeguarded from abuse and improper treatment. The provider had not ensured a safeguarding lead was in place for each location. There was no policy in place in relation to female genital mutilation (FGM) and child sexual exploitation.
  • There was poor quality monitoring of services in areas such as consent with clinicians having limited knowledge and understanding and not adhering to national guidance.
  • The provider did not hold formal, structured, minuted meetings at either provider or location level. Meetings were either held informally or were ad-hoc. Staff we spoke with told us meetings at location level were not recorded.
  • There was not an effective system in place for the reporting and investigation of incidents or lessons learned as a result. The provider did not have a process in place to ensure oversight of the reporting, recording and investigation of any incidents or significant events which may have either occurred or been reported across all locations.
  • The provider had not ensured adequate arrangements were in place across all locations to respond to emergencies and major incidents as the provider had not acted upon all previous concerns raised in a timely manner during location inspections carried out during November and December 2016.

We identified regulations that were not being met and the provider must:

  • Ensure an effective governance and leadership framework is in place to monitor the services provided and reduce the risk of harm.
  • Ensure effective systems and processes are in place for identifying, assessing and monitoring risks and the quality of the service provision across all locations such as implementing a system of clinical audits and a system of clinical supervision/mentorship and clinical oversight for all clinical staff including trainee dental nurses. Ensure all clinical staff are competent to ensure the safety of patients using the service.
  • Ensure appropriate systems are in place to properly assess and mitigate against risks including risks associated with infection prevention and control, legionella, managing emergency situations and premises and equipment.
  • Ensure a review is undertaken of chaperone arrangements and that chaperone training is undertaken by staff who perform chaperone duties.
  • Ensure arrangements to safeguard children and vulnerable adults from abuse reflect relevant legislation and local requirements.
  • Ensure effective processes for timely reporting, recording, acting on and monitoring of significant events, incidents and near misses are in place across all locations.
  • Ensure an effective process is in place to monitor patient care records so that patient information is recorded in line with the ‘Records Management Code of Practice for Health and Social Care 2016.
  • Ensure the practice's recruitment policy and procedures are suitable and the recruitment arrangements are in line with Schedule 3 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, with necessary employment checks are in place for all staff and the required specified information in respect of persons employed by the provider is held.
  • Ensure a registered manager is in place at each location. (It is a requirement of registration with the Care Quality Commission where regulated activities are provided to have a registered manager in place).
  • Review processes in place in relation to clinicians medical indemnity insurance to show that appropriate checks of clinicians own insurance is carried out prior to commencement of employment.
  • Ensure that staff taking consent have the appropriate knowledge, skills and competence. Ensure consent is sought from adults and children including those that are vulnerable in line with legislation and guidance.

There were areas where the provider could make improvements and should:

  • Ensure a system of appraisals is in place so all members of staff across the organisation receive an appraisal at least annually.
  • Ensure appropriate policies and procedures are implemented, relevant to the organisation so all staff are aware of and understand them.

Enforcement action was taken against the provider on the 15 February 2017, when we issued an urgent notice of decision to immediately suspend their registration as a service provider (in respect of all regulated activities for which they are registered) for a period of six months. We took this action because we believed that a person would or might be exposed to the risk of harm if we did not take this action.

Inspection carried out on 8 September 2016

During an inspection to make sure that the improvements required had been made

We carried out an announced comprehensive inspection of this practice on 1 March 2016. Breaches of legal requirement were found. After the comprehensive inspection, the practice wrote to us to say what they would do to meet legal requirements in relation to the breaches.

We undertook this focused inspection to check that they had followed their plan and to confirm that they now met legal requirements. This report only covers our findings in relation to those requirements. You can read the report from our last comprehensive inspection, by selecting the 'all reports' link for Polmedics Limited - Wellingborough on our website at www.cqc.org.uk

Our findings were:

Are services well-led?

We found that this practice was providing well-led care in accordance with the relevant regulations.

Background

Polmedics Limited – Wellingborough is a dental clinic that also has clinics for family planning, gynaecology and maternity situated in the centre of Wellingborough a town in Northamptonshire. The clinic caters mainly, but not exclusively, to the Polish community, and employs mainly Polish clinicians and staff.

This follow up inspection focused solely upon the dental services provided by the clinic. On the day that we visited these were the only services being offered. The clinic provides private dental services.

The practice is situated in a converted Victorian property. On the ground floor there is a waiting room with reception, the main dental treatment room and a decontamination room. In the basement there is a staff room, and storage areas. On the first floor are the second dental treatment room as well as a consulting room and a gynaecology treatment room. Toilets for staff and patients are on the first floor.

Since our last visit the registered manager has left the service, and the new practice manager had applied to be 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 practice is run.

Following our visit we were informed that this practice manager had also left the service, and another application would be made to appoint a registered manager.

Our key findings were

  • The practice had an automated external defibrillator for use in a medical emergency. An AED is a portable electronic device that analyses life threatening irregularities of the heart and delivers an electrical shock to attempt to restore a normal heart rhythm.

  • A legionella risk assessment had been completed by an external contractor, and the practice were complying with the requirements of the assessment. Legionella is a bacterium found in the environment which can contaminate water systems in buildings.

  • Audits of the service had been completed to highlight and improve quality.

There were areas where the provider could make improvements and should:

  • Review the practice's protocols for completion of dental records giving due regard to guidance provided by the Faculty of General Dental Practice regarding clinical examinations and record keeping.

Inspection carried out on 1 March 2016

During a routine inspection

We carried out an announced comprehensive inspection on 1 March 2016 to ask the practice the following key questions; Are services safe, effective, caring, responsive and well-led?

Our findings were:

Are services safe?

We found that this practice was providing safe care in accordance with the relevant regulations.

Are services effective?

We found that this practice was providing effective care in accordance with the relevant regulations.

Are services caring?

We found that this practice was providing caring services in accordance with the relevant regulations.

Are services responsive?

We found that this practice was providing responsive care in accordance with the relevant regulations.

Are services well-led?

We found that this practice was not providing well-led care in accordance with the relevant regulations.

Background

Polmedics Limited – Wellingborough is a dental clinic that also has clinics for family planning, gynaecology and maternity situated in the centre of Wellingborough a town in Northamptonshire. The clinic caters mainly, but not exclusively, to the Polish community, and employs mainly Polish clinicians and staff.

We carried out a comprehensive inspection on the dental services provided by the clinic. On the day that we visited these were the only services being offered. The clinic provides private dental services.

The practice is situated in a converted Victorian property. On the ground floor there is a waiting room with reception, the main dental treatment room and a decontamination room. In the basement there is a staff room, and storage areas. On the first floor are the second dental treatment room as well as a consulting room and a gynaecology treatment room. Toilets for staff and patients are on the first floor.

The practice 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 practice is run.

We received feedback from patients we spoke with on the day of our visit. The feedback reflected positive comments about the staff and the services provided. A patient commented that explanations about their treatment were clear and that and all options were fully explained.

Our key findings were:

  • There was appropriate equipment for staff to undertake their duties.

  • The practice seemed clean and clutter free.

  • Patients commented that staff were kind and friendly, and we observed staff welcoming patients in a polite and caring fashion.

  • The practice is open 7 days a week with late evening appointments so patients can be assured of getting an appointment at a time that suits them.

  • The practice protocols for decontamination of dental instruments were in line with current national guidelines, with the exception of testing of one piece of equipment, which had subsequently been implemented.

  • Staff recruitment checks had been carried out in accordance with schedule three of the Health and Social Care Act 2008. Disclosure and barring service checks had been carried out on all staff to ensure the practice employed fit and proper persons.

  • Staff had a good understanding of how to raise a safeguarding concern, and when to do so. Contact numbers were readily available on the premises.

We identified regulations that were not being met and the provider must:

  • Ensure audits of various aspects of the service, such as radiography and infection control are undertaken at regular intervals to help improve the quality of service. The practice should also ensure all audits have documented learning points and the resulting improvements can be demonstrated.

  • Ensure that clinicians are up to date with evidence based guidelines for care and treatment such as the National Institute for Health and Care Excellence guidelines, guidance from the Faculty of General Dental Practitioners and General Dental Council standards for the dental team.

You can see full details of the regulations not being met at the end of this report.

There were areas where the provider could make improvements and should:

  • Review the information documented in dental care records giving due regard to guidance provided by the Faculty of General Dental Practice regarding clinical examinations and record keeping. Also recording in the patients’ dental care records or elsewhere the reason for taking X-rays giving due regard to the Ionising Radiation (Medical Exposure) Regulations (IR(ME)R) 2000.

  • Review the practice’s arrangements for receiving and responding to patient safety alerts, recalls and rapid response reports issued from the Medicines and Healthcare products Regulatory Agency (MHRA) and through the Central Alerting System (CAS), as well as from other relevant bodies such as, Public Health England (PHE).

  • Review the practice’s system for the recording, investigating and reviewing of incidents or significant events with a view to preventing further occurrences and, ensuring that improvements are made as a result.

  • Review availability of equipment to manage medical emergencies giving due regard to guidelines issued by the Resuscitation Council (UK), and the General Dental Council (GDC) standards for the dental team.

  • Review the practice’s protocols for the use of rubber dams for root canal treatment giving due regard to guidelines issued by the British Endodontic Society.

  • Review the practice’s infection control procedures and protocols giving due regard to guidelines issued by the Department of Health - Health Technical Memorandum 01-05: Decontamination in primary care dental practices and The Health and Social Care Act 2008: ‘Code of Practice about the prevention and control of infections and related guidance.
  • Review the necessity for a competent person to carry out a legionella risk assessment of the premises giving due regard to the guidelines issued by the Department of Health - Health Technical Memorandum 01-05: Decontamination in primary care dental practices and The Health and Social Care Act 2008: ‘Code of Practice about the prevention and control of infections and related guidance.
  • Review its responsibilities as regards to the Control of Substance Hazardous to Health (COSHH) Regulations 2002 and, ensure all documentation is up to date and staff understand how to minimise risks associated with the use of and handling of these substances.
  • Review the practice’s sharps procedures giving due regard to the Health and Safety (Sharp Instruments in Healthcare) Regulations 2013.

  • Establish whether the practice is in compliance with its legal obligations under Ionising Radiation Regulations (IRR) 99 and Ionising Radiation (Medical Exposure) Regulation (IRMER) 2000.

  • Review the practice protocols and adopt an individual risk based approach to patient recalls giving due regard to National Institute for Health and Care Excellence (NICE) guidelines.

Inspection carried out on 7 August 2013

During a routine inspection

On the day of our visit only one dentist and one nurse were at the practice. The Nominated Indivual was on holiday and not available. We spoke with the new owner on the telephone in order to clarify some questions about the registration of the practice with the CQC. The Registered Manager details on this report refer to the previous manager, who is no longer at the service, but who has not yet advised us of any changes. The Provider will wish to make these changes accordingly.

The practice also provides family planning,maternity and midwifery services. However, we were not able to speak with anyone about those services on the day of our visit.

We found the practice was clean and well presented, with a combined reception and waiting area. The dental surgery was on the ground floor.

We spoke to patients who used the dental practice. They told us they were happy with the services they received. One person told us, “If I wasn’t happy I wouldn’t come here.”

Another person we spoke with told us, "All my family come here too, we are happy with the dentist."

We looked at some of the patient records and some of the Providers policy documents.

Inspection carried out on 18 May 2012

During a routine inspection

No people who used the service attended Polmedics on the day of our inspection. However, we saw a compliments book and questionnaires that people had used to provide feedback about their experience of the service. The comments were positive. All respondents indicated that they were satisfied with the level of service. All respondents indicated that their doctor had provided satisfactory answers to their questions. When answering questions about doctor's competence, surgery equipment and the cleanliness of the premises, all respondents rated those as `very good.'