Infection Control: Precepts and Practicalities

1. Infection Control:Precepts and Practicalities

2. Objectives By the end of this presentation, you will: have a better understanding of Health and Social Care Act 2008 and the related regulations have a better understanding of the issues regarding your registration requirements with the Care Quality Commission and how to get further advice

3. Healthcare Regulations Explained

4. ACTS and REGULATIONS Any act of Parliament (in other words, law), normally consists of a number of Regulations that focus on specific aspects of that particular law (a good example is the Health & Safety at Work etc. Act 1947 with lots of specific regulations, e.g. Manual Handling, Display Screen, etc.): An act of Parliament (law)

5. ACTS and REGULATIONS (cont.) The same is true for the Health and Social Care Act (HSCA) 2008, which has two regulations specific to this discussion: HSCA

6. Regulated Activities Regulations

7. Care Quality Commission (Registration) Regulations 2009 This regulation has brought into existence the new health and social care regulatory body the Care Quality Commission (CQC). Those who carry out any regulated activity (including completely independent providers) are required to register with the CQC.

8. The Health and Social Care Act 2008 Please remember that the Health & Social Care Act 2008 and its related Regulations are law and must be complied with

9. Health and Social Care Act 2008 (cont.) As well as a number of regulations, most laws have guidance documents or codes of practice which are meant to help those to whom the law applies interpret and put it into practice more easily.

10. The Code of Practice The Code consists of 10 criteria, not all of which (you would be glad to know) are applicable to dentistry. Below are some examples (in abbreviated form) of these criteria: Systems to manage and monitor the prevention and control of infection; involving risk assessment Provide and maintain a clean and appropriate environment Ensure that all staff are fully involved in the process of preventing and controlling infection. Have and adhere to policies Ensure, so far as is reasonably practicable, that care workers are free of and are protected from exposure to infections

11. Some pointers from the �code� By following the Code � primary care � registered providers will be able to show that they meet the regulation on cleanliness and infection control. Organisations that commission services from providers of regulated activities need to assure themselves that providers are able to demonstrate compliance with the Code. The Code does not replace the requirement to comply with any other legislation that applies to health and social care services; for example, the Health and Safety at Work etc. Act 1974 and the Control of Substances Hazardous to Health Regulations 2002. The CQC has tough new enforcement powers that it may use if registered providers do not comply with the law.

12. How will the CQC regulate your activities? They state that their assessment will be focused on outcomes rather than systems and procedures By �outcomes� they mean �the experiences we [the CQC] expect people to have as a result of the care they receive � rather than primarily [focusing] on policies �� They state: �we want people to have a bigger say in how we judge whether providers are meeting essential standards� [although it is not certain yet how exactly they will achieve this]

13. How can you produce evidence on your outcomes? This is what the CQC suggests: �Your own auditing, monitoring, benchmarking against other services, feedback from PCT commissioners and other inspection activity, and feedback from patients are all examples of outcome evidence that you may be able to use in deciding whether or not you are compliant� You need to start thinking about how you are going to gather this type of information. The quarterly infection control audits as required by the HTM 01-05 will help you with this (more of that later)

14. Let�s have a quick recap The Health and Social Care Act 2008 applies to all providers of health and social care, among whom are dentists, including those who may be completely independent of the NHS As providers of a regulated activity dentists are required to register with the Care Quality Commission When you register with the CQC you are required to demonstrate that you meet the essential standards of quality and safety The CQC is more interested in the outcomes of your activities rather than systems, policies, etc.

15. Registering with the CQC First of all, be aware that registration is your legal licence to operate. The term �essential standards of quality and safety� has been mentioned a few times so far, because this is what your registration criteria are based on. These standards are grouped into six broad categories as shown in the next slide, the details of which you can read in the relevant CQC literature. However, the following two examples will give you a better idea.

16. Essential standards of quality and safety (ESQS) Involvement and information Personalised care, treatment and support Safeguarding and safety Suitability of staffing Quality and management Suitability of management.

17. Examples of ESQS Involvement and information Safeguarding and safety

18. ESQS (cont.) Remember that you are expected to have evidence that you meet the outcomes Outcome 1: Respecting and involving people who use services Outcome 2: Consent to care and treatment Outcome 3: FeesOutcome 1: Respecting and involving people who use services Outcome 2: Consent to care and treatment Outcome 3: Fees

19. How and when will you need to register? CQC may have notified you directly; if not contact them yourself ASAP The registration is meant to be carried out online Start with �enrolment� and �verification of details� (see next slide) After enrolment your will be given a 28-day window between 15 November 2010 and March 2011 to submit your application There is plenty of guidance on the CQC website

20. Online registration 1

21. Online registration 2

22. Registration: what happens next? CQC will publish a register of providers on their website The registration only happens once but is not just about initial application There will be continuous monitoring of compliance with essential standards A �reactive review� is triggered: When information or a gap in information raises concern It will be targeted to the areas of concern May include a site visit A �planned review� will take place within 2 years of registration

23. What should you be doing to prepare yourself? Read the latest guidance on the CQC for dentists (check their website) Do the same for registration requirements Subscribe to their newsletter: http://www.cqc.org.uk/newsandevents/newsletter.cfm Contact the National Contact Centre on 03000 616161 Check your own internal reporting and audit systems Consider evidence on outcomes

24. A final thought on registration with the CQC The most important point to take away � Documentation, Documentation, Documentation! �� we [the CQC] will expect you to have information available from your own internal monitoring and quality assurance systems, if we ask to see it. We will publish templates on our website to help you maintain such information and keep it up to date.�

25. How can you be better equipped to deal with the CQC requirements? Study the Health Technical Memorandum 01- 05 (learn it by heart � OK, just kidding but do become very familiar with it) Paragraph 1.12 in the HTM states: �Following the guidance in this document [HTM 01-05] will help to achieve a satisfactory level of risk control together with equivalent compliance with the �essential requirements� of the regulations.�

26. Compliance with the HTM 01-05 Compliance with HTM 01-05 will satisfy CQC Outcome 8, which just to remind you was To help you meet the Essential Quality Requirements (EQR) I sent you a self-assessment template in electronic or paper form (see next slide), which some of you have completed and returned. If you haven�t already done so completing it will help you: Identify areas of lack/improvement Produce an action/implementation plan regarding the above Best practice requirements: This is not required for registration However, you must have a detailed plan to show you are working towards it (according to the HTM 01-05)

28. Above all, don�t get too frustrated! Don�t let the business of registration and the HTM 01-05 get to you, like it has got to this chap (if nothing else, bad for your teeth, I�m sure you will agree)! Take every opportunity to learn more about both. YOU CAN DO IT