23 January 2012
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Providers must have regard to the Code of practice for health and adult social care on the prevention and control of infections and related guidance, The Code. The Code is to be taken into account by CQC when making a decision. A registered provider may be able to demonstrate that it meets the regulations in a different way (equivalent or better) from that described in The Code of such activity.
Compliance
Using evidence of outcomes to demonstrate compliance
When completing an application for registration a provider must declare compliance or non-compliance with each regulation. If a provider is non-compliant this must be declared and at the same time a compliance plan must be submitted with details of how the provider will become compliant and the timescale.
A provider who demonstrates insight in identifying and declaring non-compliance and submitting an appropriate compliance plan is likely to be in a better position than a provider who declares compliance and is later found not to be in a position to demonstrate compliance.
When CQC monitors your compliance with the Essential Standards, it will check that you are meeting these outcomes. CQC will focus on evidence which demonstrates that people who use services:
- Have good outcomes and experiences, meaning that their care is effective and that they are safe.
- Are involved in their care and that their views are listened to and acted on.
- By focusing on outcomes rather than looking only at a provider’s policies and procedures, CQC states that it can assess health and social care services in a way that is centred on people who use services. This means actually considering the effect that a service has on people.
The evidence a provider uses may be influenced by the factors in the service it provides. For example, you could use evidence directly from people who use services and those acting on their behalf, such as:
- Surveys of people who use services, their carers and families.
- Feedback from people who use services.
- Patient reported outcome measures (PROMs).
- Feedback from other sources eg local groups.
Many dentists are used to collecting feedback from patients. In reality patient feedback is a valuable practice development tool. It collects the views and opinions of patients and service users on the care they have experienced. There are different ways of collecting feedback including the use of anonymous feedback forms, comments books, audits, complaints and compliments. Some practitioners have also used, one-to-one interviews and focus groups. Once you have collected the feedback you need to review it and decide how to use it to continue to develop your practice. A useful next step is to then inform patients of how their feedback has been used and what changes have been made. This could be done in the practice newsletter or by way of information in the waiting room. In this way patients feel more involved in the practice.
When you evaluate your own compliance, CQC expects you to focus on evidence that relates to outcomes for people. However, CQC recognises that you may not be collecting direct outcome evidence for all services or all outcomes. Therefore, it anticipates a greater initial emphasis on evidence from policies, procedures and systems. It is therefore appropriate to consider this in relation to the impact that they have on people who use your service.
As the system for ongoing monitoring of compliance is embedded, CQC will increasingly expect you to gather and use evidence that directly demonstrates outcomes or comes directly from people who use your service. Carrying out infection control audits and sharing the results appropriately with patients and the dental team may be a helpful way to assist you to demonstrate your compliance.
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Resources
Available from Dental Protection
- Dental Protection Risk Management Module 22 - Cross infection control
DPL members can click here to access this document from DPL's new E-learning portal
In order to demonstrate compliance members will want to put themselves in the position to demonstrate that they have appropriate and effective infection control procedures in place which takes into account the regulations and guidance.