Posted: 9 May 2012
CQC: Suitability of staff
Continuing her series on the Care Quality Commission, Seema Sharma highlights how important recruitment and team training are in developing strategies for success
Too many practices have misinterpreted Care Quality Commission regulations to believe they are all about having policies and procedures. Rather, they form a rulebook, which defines the processes in a practice. These processes are then put into place by the team to lead to outcomes, which are delivered by people.
CQC is a turning point for all practices because every team member’s actions could impact on the outcomes for patients. Team training and empowerment are therefore integral to developing strategies for success and showing that teams can ‘walk the walk’, whilst practice owners and managers ‘talks the talk’. Without comprehensive training, your team could well become your Achilles’ heel.
To decide on the level of concern for each scenario, CQC inspectors would:
• Consider the impact on patients
• Consider the likelihood that it will happen again
• Apply this matrix to decide if the practice is compliant or they have minor/mod/major concerns.
It seems hard to believe sometimes, but CQC outcomes are about the patient. For every gap that CQC identifies, an assessment of the impact on the patient will be graded high, medium, low or problem-free (compliant).
If the outcome is not compliance, the likelihood that an adverse impact could recur will determine the CQC’s ‘level of concern’, and this depends on the evidence the practice can provide of training and learning from mistakes.
Just one major concern will tip a practice over the highest threshold, as will three moderate concerns and three minors; two moderates and six minors; one moderate and nine minors or 12 minor concerns. Regulatory action will then be determined and applied. There is a differing approach for practices that have declared non-compliance and submitted action plans, compared to those that declared compliance but where concerns were identified. The full guidance on how compliance will be assessed can be found in the CQC’s guidance titled, Setting the bar. This can be found on the CQC’s website at www.cqc.org.uk.
With up to three minor points, you will get a chance to work to an action plan. If your practice scores between four and 11 points, and you did not declare compliance, CQC will not be happy and you could end up with a compliance condition. If you declared non-compliance and submitted an action plan, you might get away with an improvement letter.
There is time to significantly reduce the likelihood of concerns by aligning the practice vision with that of the regulators. Compliance is a whole team effort and never before has excellent leadership been so essential. A good leader creates vision for the practice and a good manager knows how to implement that vision by selecting appropriate team members for each role, and nurturing their individual strengths.
Table 1 shows the scope of human resource (HR) systems that a practice should have in place to demonstrate that the team is fit for purpose.
|TABLE 1: 10 ESSENTIAL HR PROCESSES|
|2. Pre-employment checks|
|3. Contracts/licences (including pay and conditions)|
|5. Familiarisation with practice policies and procedures|
|6. Staff rotas accommodating planned absence|
|7. Management of unplanned absence|
|9. Continuing professional/personal development|
|10. Individual health, safety, welfare and support.|
A practice’s recruitment and selection processes and procedures must be fair, equitable and transparent. Practices should promote equal opportunities and anti-discriminatory practices, and comply with legislation including the protection of children and vulnerable adults.
Practices are expected to comply with relevant legislation during recruitment, including:
• The Equal Pay Act 1970
• The Sex Discrimination Act 1975
• The Race Relations Act 1976
• The Disability Discrimination Acts 1995/2005
• The Employment Rights Act 1996
• Employment Equality (Age) Regulations 2006
• Employment Equality (Religion or Beliefs) Regulations 2003
• The Employment Equality (Sexual Orientation) Regulations 2003.
To deliver outcomes, dental practice owners need to ensure they have the right staff with the right skills, qualifications, experience and knowledge to look after patients and the practice. When recruiting a new team member, it is sound practice to conduct and record the following six key employment checks:
1. Verification of identity
2. Right to work
3. Registration and qualification
4. Employment history and references
5. Criminal records
6. Occupational health.
There is also a range of additional checks, which should be carried out to determine the candidate’s suitability, such as professional indemnity registration, clinical capability and an understanding of the General Dental Council’s Principals of dental team working. These standards apply to permanent and temporary staff.
To establish a clearly defined relationship from the outset, each employee should be provided with a written statement of the terms and conditions under which they are engaged, outlining their job description, practice polices (including sickness), pay level, holidays and the practice grievance procedure and disciplinary procedure.
Self-employed contractors should also be given written terms and their expected code of conduct, in the form of a licence, to avoid ambiguity without turning them into employees. Properly designed licences are available from the Dental Practitioners’ Association.
By developing detailed induction programmes for all members of the team, practice owners can ensure that new team members are integrated smoothly. Longer standing members of the team should be re-orientated, in light of the new regulations (induction and re-orientation will be covered in more detail in the next article).
To improve outcomes, staff training needs should be identified and supported, with protected time for learning and development to optimise the team’s skills, happiness, performance and staying power! Ideally a practice should have systems for developing each team member in all aspects of clinical care and compliance with quality frameworks such as CQC. The quality of the service being provided by the team should be audited regularly and training arranged to align the skills and work of those who are not on track. This is a potentially expensive area, and digital training and mentoring can often provide the most cost-effective solution.
All team members should have an annual appraisal and discussion of personal and professional development plans to ensure that their individual training needs are assessed and met, and they are kept up to date with current practice, ensuring their suitability for their role is not compromised. Appraisals provide an opportunity to look back at the training needs that were identified at an earlier point in time, and see if the team member is on track for each subject.
Regular risk assessments of health and safety in the practice, and compliance with human resources guidance and legislation, including CQC, will ensure that staff welfare is given priority at all times. It is also important for the practice to be supportive of individuals with personal problems, when appropriate.
|KEY POINTS: CONSIDERATIONS FOR PRACTICE MANAGERS|
|• Define individual roles|
|• Create clear job descriptions for all roles|
|• Ensure advertisements clearly outline the role which the candidate is applying for|
|• Treat all applicants equally by using template interview forms and processes|
|• Offer the job in writing and provide written terms and conditions (contracts or licences)|
|• Conduct thorough checks prior to employment|
|• If the new staff member has a probationary period, ensure the details are outlined in the offer letter|
|• Put new staff members through an induction process|
|• Provide all team members with a staff handbook/team manual outlining practice policies and procedures|
|• Organise and record all staff training and continuing professional development|
|• Monitor individual performance|
|• Conduct annual appraisals for all team members|
|• Ensure that all team members have personal/professional development plans to maintain and develop their individual skill sets|
|• Be aware of the human resource legislative frameworks around working times, holidays, rest breaks, disciplinary procedures, stress, disability, for example.|
|To read other articles in the CQC series, please click below:|
|CQC in practice management|
|Will you walk the walk?|
|Organisation is the key to compliance|
|The value of consent|
|Information security procedures|
|Equality, diversity and human rights|
|Supporting workers (Part I)|
|Supporting workers (Part II)|