Taking a risk-based approach to inspection activity over winter
Ted Baker discusses the focus for our risk-based inspection activity over the coming months, as well as the impact of whistleblowing on how we regulate.
I want to start by saying thank you once again to all of the staff who continue to work tirelessly in health and social care across the country. Winter puts tremendous pressure on the system, and to manage this alongside the added challenge of COVID-19 is a monumental achievement and testament to the effort of staff on the front line.
This year we have seen a marked rise in the number of whistleblowers contacting us and information of concern from healthcare staff as well as from members of the public. It is important that people feel able to speak up during the pandemic — and COVID-19 appears to have strengthened the culture where people see the value of sharing their concerns. Staff have been going to extraordinary lengths to deliver good, safe care during this global crisis. If they are experiencing barriers to the delivery of that care, we want to hear from them and we are encouraged that so many staff have been brave enough to raise concerns with us. Concerns raised by whistleblowers have been a key part of our transitional regulatory approach, as well as being vital to the way we assess the risk in a service. Between 1 April and 1 December the majority of hospital inspections were trigged by information of concern shared by staff or members of the public. The number of whistleblowing concerns received during November 2020 was 58% higher than the same period last year.
Our Give feedback on care form was created so that staff and members of the public could easily share concerns if they have them, as well as letting us know about positive experiences of care. I encourage you to use this if you have feedback to share.
‘Concerns raised by whistleblowers have been a key part of our transitional regulatory approach.’
As our transitional regulatory approach is risk-based we will be carrying out targeted inspections, focusing on the areas that we see as posing the most risk and where we have received concerns. Our key priorities for this winter and the areas we will focus on are:
· infection prevention and control
· the impact of winter on emergency departments
· the safety of maternity services.
I want to explain why we are focusing on these areas, to reinforce the fact that this is in line with our risk-based approach and to assure you that any on-site activity will be carried out in a way which minimises the impact on service provision.
The impact of winter on emergency departments
This will be the third year that we have carried out one-day, targeted inspections of emergency departments in the winter. With the added pressures of COVID-19 it is imperative that we continue these inspections this year, to be assured that trust boards are supporting emergency department staff to work collaboratively with other hospital departments and local services to prioritise safety and protect people from risk. In previous years we have had positive feedback from providers that have received a focused winter inspection, and we hope that having the smaller, clinically-led inspection team on site for one day will continue to be a successful and supportive approach. I also hope you have read our recently published Patient FIRST resource, which was developed in partnership with a group of frontline clinicians from good and outstanding emergency departments across the country. It looks to support those working in NHS trusts and the wider health and care system to understand what lessons can be learnt from the impact of the pandemic, and what good practice can be harnessed to support improvement.
Infection prevention and control
The importance of effective Infection prevention and control (IPC) in maintaining patient safety has been brought into sharp focus by the COVID-19 pandemic. Throughout July and August we had conversations with trusts to see how they were addressing the risks of cross infection and assuring themselves that they were meeting national guidance on IPC. Following on from this, we now plan to inspect services where we identify concerns about how IPC is planned and managed. These inspections will be carried out as focused well-led inspections, using a modified well-led inspection framework which specifically considers IPC issues. The well-led key questions will remain, but with IPC prompts and questions added in where appropriate.
From our ongoing monitoring of maternity services, we know that overall there are concerns — particularly around safety. As the regulator we are seeking assurance that people using these services are receiving safe care. Currently 39% of maternity services are rated requires improvement for ‘safe’. Therefore, when we visit services that we have concerns about, we will be focusing on the safety culture. The inspections will be led by a local inspector who knows the service, and supported by one of our specialist advisors, as well as an ‘expert regulator’ with experience of maternity services — like a practicing midwife. Our maternity regulator will be involved in the end-to-end process for each inspection to ensure consistency, and they will help draw out themes across the whole programme. If you have not already I encourage you to read our briefing ‘Getting safer faster’ published in March, which is intended to help maternity services, their trust boards and stakeholders to focus on the action they can take to improve and ensure that women and babies get consistently good, safe care.
All these inspections will be based on risk, in line with our transitional regulatory approach, and will be carried out taking into account the increased pressures currently impacting on hospital services and staff. We are visiting services where we have concerns to make sure people are receiving safe care, and we want to support providers to do this.
‘All these inspections will be based on risk, in line with our transitional regulatory approach.’
Finally, inspections are always an opportunity for staff to highlight where they have concerns and tell us the reality of the issues they are facing, allowing us to escalate this where necessary and potentially influence action from NHS England and Improvement, and the Department of Health and Social Care. I hope if you work in a service which we visit this winter you will use this opportunity to share your feedback with us.