How the early intervention of a Health and Social Care Consultant can have a positive impact

A large part of our work at Swift Management is working with providers from all areas of the health and social care sector, who find themselves in an enforcement situation with the regulators. In England, this being the Care Quality Commission. There is a view that consultants are expensive, but brought in sufficiently early high costs can be avoided.

Many of our clients call us or are referred to us by their solicitor when they are facing a Notice of Proposal or worse a Notice of Decision. This means they have had problems for quite some time and have not taken sufficient action to make the changes required by the regulator.

The team at Swift Management believes that very early intervention can stop situations escalating and result in a cost-effective solution avoiding enforcement action being taken.

We recommend that as soon as a provider receives an inspection report with the rating of “Inadequate” they contact a consultant immediately and before they complete the factual inaccuracy form. A well written evidenced-based Factual Inaccuracy form can really help. We can send a consultant to site to review the report and find any evidence to support a challenge within a very short space of time.

We are then able to complete a full audit of all the CQC KLOE’s and write an action plan to move the service forward before the next inspection and if required we can attend meetings with the regulators with a provider to help explain the situation. The involvement of a consultant is always viewed as positive by regulators.

During the period between inspections, we can provide both on-site support & regular reviews and updates to the action plan, which if required we can then forward to the regulatory inspector to demonstrate that improvements are being made. With our assistance and the provider’s cooperation we would expect service to have significantly improved by the next inspection and the rating to no longer be Inadequate. This prevents further enforcement action being taken and removes the need to take matters further.

When a provider has not engaged the services of a consultant and second inspection results in an inadequate rating being given, the provider can expect to receive notification of enforcement action being taken. This is usually in the form of a Notice of Proposal. A provider has 28 days in which to respond. This requires a different and very decisive response. Again, this is something we can assist with but provides a much narrower timeframe in which to work. It will often involve a two pronged approach with the use of a solicitor as well as a consultant. The aim is to prevent the Notice of Proposal moving to a Notice of Decision. In the event that a Notice of Decision is issued, all is not lost and one of our senior consultants is able to work with your solicitor to consider making representation to a tribunal and building the evidence portfolio to demonstrate compliance.

The legal route of enforcement is a long, time consuming and expensive one. The team at Swift Management Services recommend engaging a Care Consultancy at the very early stages; that is to say the very first draft inspection report rating a service receives an Inadequate, it is vital to both minimalize reputational damage and bring about the changes required to halt the process and improve ratings at the next inspection.

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The Swift Management KLOE Inspection process

CQC has a framework of inspection based on what is known as “the KLOE’s”. The term KLOE stands for Key Lines of Enquiry. They are based on best practice and the evidence from the KLOE goes to make up the care providers rating in the five categories of Safe, Effective, Caring, Responsive, and Well Led.

Some of our provider’s comment that their inspection report is repetitive and one or two points have been used in a number of categories, this is because the KLOE inspected has an impact on more than one categories, for example, a medication error caused by a number of staff members could impact on Safe, Caring and Well Led.

The information that CQC gathers throughout the year from many different sources is used as part of the inspection process and allows the inspection team to focus on various aspects of your service using the KLOE’s. When the inspection takes place the inspector already has a lot of information about your service and so it is important for the Manager and the team at the home to showcase the excellent work they do.

There is never a good time for the inspection team to arrive, we all know in a care home, every day is different, and something is always pulling the manager in one direction or another. That said the inspection is a snapshot of the home and depending on how everyone performs will significantly influence the outcome of the inspection. The Swift Management KLOE inspection documentation is designed to help at the time of your CQC inspection as it signposts the good practice.

When we carry out a KLOE inspection you will receive a visit from two consultants, usually unannounced but pre-arranged. This is to make the inspection as real as possible. One consultant carries out an inspection in much the same way as an inspector from CQC would do.

Whilst the second Consultant works with the manager to draw out evidence good or otherwise to support every KLOE. This then provides the home with a comprehensive report, which not only givens you a summary of the day, but details the evidence seen along with an assessment of standards and potential grade for each KLOE. The assessment can then be fed into the Service plan to make any improvements. The very positive aspect of this style of report is the evidence used to make the assessment is listed, meaning if used at the time of a CQC inspection, the manager is able to put forward all the evidence they will need to make their assessment. Given that an inspection is a snapshot of the care home, the more detail you provide the better the picture of the home will be. The Swift Management KLOE inspection report has assisted our clients to have at hand the evidence they need ensuring nothing is missed.

Where things need improvement the service plan produced by Swift Management provides the inspectors with a transparent and honest action plan, with not only the issues but how, and by whom the action is going to be taken and how they are going to be monitored. Any inspector knows that there is no perfect care home, and there are always improvements to be made, but a home that knows, understands, and owns the issues before they are pointed out by a CQC inspection is certainly well led.

Our clients have found our KLOE inspection audits have assisted in the formal CQC inspection process for many reasons. The first being staff have practiced an inspection. The second being there is an action plan to address issues before they are raised. The third being the inspectors are provided with the evidence they need to make a sound judgment because nothing is missed.

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