CQC’s latest infection control guidance
The Care Quality Commission recently published their guidance on infection prevention and control to look at how well staff and residents living in care homes are protected from infection (key line of enquiry S5) and to help providers and managers plan ahead for the anticipated next wave of the pandemic and winter pressures.
Good points are made in a number of areas such as visiting arrangements and admissions management and there are many helpful links, but CQC’s guidance overlooks some vital points as it does not use or reference the wider KLOEs to broaden its infection control advice. There is for instance little on the importance of providers’ own checks and audits and management of continuous improvement. Faultless mask wearing and handwashing need to remain the order of the day and so emphasis on the management of compliance in these areas would have been helpful.
Effective infection prevention and control relies on staff’s fitness to practise these techniques safely. Checking understanding and competency, return to work interviews to help ascertain fitness and the management and support needed to help mitigate the chances of tired overstretched staff making infection control mistakes are missing in the main body of the guidance.
The importance of investigating infection spread in managing the prevention of recurrence, local monitoring for outbreaks and the provider’s abilities to be proactive in the resulting action they take, could have been helpful features in CQC’s main guidance document. Their donning and doffing advice makes no mention of the differences between source isolation for those residents with infection or potential infection, and protective isolation techniques which help safeguard the most vulnerable.
There also seems to be no reference to care planning for residents with COVID-19, the place to encapsulate all the information needed to effectively support each individual whilst minimising the risk of spreading the infection.
So, whilst CQC’s guidance is welcomed, it should only be used as a foundation from which providers can build and develop their own management systems to minimise the risk of cross infections, particularly in relation to this pandemic.
Minimising infection control risks during a CQC inspection
CQC have indicated they intend to carry out more inspections as part of their Transitional Regulatory Approach which is being introduced from September. Until now CQC has limited inspections during the pandemic to perceived high risk services but that is going to change. They will start inspecting services where they have evidence that care needs to improve which encapsulates a far larger number of services.
CQC says that they will exercise a balance between making an accurate assessment of quality, while minimising infection control risks. In their COVID-19 update of 14 August CQC state:
“Our priority is to ensure the safety of people using services, your staff and our colleagues. We are, therefore, taking the following measures:
- Thorough risk assessments ahead of all inspection and registration visits
- Provision of PPE for colleagues undertaking on-site activity, and training in how to don and doff correctly
- Training in infection prevention and control.”
To ensure risks are managed on an informed basis, there ought to be some notice given of the inspection, unless the situation is so pressing as to require an unannounced visit to take place which will only be in a minority of cases. CQC should share its risk assessment with the provider before the inspection, with the service sharing its current visiting policy. There ought to be a discussion either before or at the outset of the inspection as to how it will be conducted. For example, if there are COVID-19 infections on the first floor of a service, the provider might suggest the inspectors do not access that area. Effective communication will be essential throughout the inspection to ensure risks are managed.
The importance of inspectors following proper infection control procedures is all the more important given that they will not be subject to routine asymptomatic testing on a weekly basis as they do not meet the criteria for such testing. Consequently, inspectors could have inspected a service with a COVID-19 outbreak in the previous 14 days before coming to your service. One would hope that such a scenario would be considered as part of CQC’s risk assessment. As a provider you have rights and responsibilities so if you are concerned about any aspects of the proposed inspection you should flag that up with the inspection team and, if necessary, escalate it within CQC. The primary consideration must be the health, safety and well-being of those people you care for, while not forgetting the obligations you owe to your staff as well.
Conclusion
Services will need to ensure their audit tools in relation to infection prevention and control are comprehensive and detailed. While CQC’s latest guidance provides some assistance, it should not be seen as the “alpha and omega” of dealing with infection control as there are some notable omissions. Ultimately, registered providers and managers are responsible at law for the operation of their services. That means being active in monitoring and addressing infection control risks in relation to service users, staff and visitors, and also inspectors in terms of how inspections are conducted.
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