Welcome to the second edition of the 'Practical Guide to Compliance' series. This series is intended to act as informal guidance to dental teams working toward CQC compliance. The contents of these articles are based on personal opinion and interpretation of the CQC framework and other relevant legislation. Whilst the author has full confidence in the suitability and appropriateness of the information contained within these articles, the information shall not be regarded as fact and those requiring definitive information should consult the relevant governing body.
Outcome 2- Consent to Care & Treatment
What do the regulations say?
“Before people are given any examination, care, treatment or support, they should be asked if they agree to it”.
- CQC Essential Standards
Compliance to outcome 2 is all about making sure your patients are given the support and information to make an informed decision about their care, it requires you to have procedures in place to determine whether an individual lacks the competence to make a particular decision and for each member of the team to know what to do in this situation. For those that are considered competent, we need to be providing them with all the information relevant to their care this could include discussion of treatment options, information leaflets, videos or online information. We must make the patient fully aware of all advantages, disadvantages and alternatives for all treatment and ensure that they are fully informed before asking them to make any decisions.
Consent is not a new term in dentistry it is something we have all worked with for a long time but now is a good time to review your policies and procedures to make sure they are meeting the requirements of outcome 2 and any relevant legislation.
Through using the 4 stages of compliance method you can ensure that your practice and your team are covering all the bases for this outcome.
The first stage will see the creation and implementation of a solid consent policy, one that takes the Mental Capacity Act into consideration to ensure there are clear procedures in place for assessing competence and guidelines in place for dealing with a patient who is not considered competent.
Your consent policy should outline the procedure for gaining consent, how it is obtained and how it is recorded.
You should also have patient information available for all procedures, leaflets are a good option as they can be handed out to patients after a discussion to allow them to have a reference for what has been discussed. Other forms of information can also be used such as educational videos, handouts and directing the patient to an online source of information. Regardless of what information you provide and how you provide it, it is advisable to record that you have done so.
Consent forms are also a useful way to present information to patients as they will focus their attention to the important information such as potential risks or side effects that may alter their choice of treatment. It is important to remember that a signed consent form does not constitute as informed consent, these should be used as a means for providing information but not as the only way of confirming that the patient understands what has been said.
The Mental Capacity Act 2005 has a published code of practice which provides guidance to anyone who is working with and/or caring for adults who may lack capacity click here to download this document.
Dental Protection has produced a useful document on consent click here to download it. The GDC document ‘Principles of Patient Consent’ is also useful guidance click here to download it.
So now that you have laid the foundations for compliance to outcome 2 you can now move onto stage 2- train your team. Your team should undertake some training on Consent and the Mental Capacity Act to ensure they have a thorough understanding of the subject as this will help them apply the principles to their day to day work.
As a team you should agree the implementation of your consent procedures and also agree a consistent method of recording consent, this will allow for much easier monitoring of compliance at a later stage.
It is important that your team understand what is considered valid consent. All discussions with patients should be recorded with consent in mind, did you explain the procedure, did you invite questions, did you give satisfactory explanations, were all the patients questions answered, did you verbally confirm that the patient understood what had been said and most importantly did the patient agree to the procedure? These are all important questions that need to be applied to every treatment discussion.
So you’ve laid the foundations and you have trained your team, it’s now time to practice, practice, practice! Implement the procedures and the learning that has occurred and apply this to your daily work.
You are almost there, now that you have everything in place you must monitor and review to achieve ongoing compliance. This could involve audits of consent and patient records, team quizzes and spot tests or even patient surveys. The important thing is that you regularly measure the effectiveness of your procedures and make any necessary changes when things are not working. As part of this process it is important to stay abreast of any changes in legislation that may affect how you work.
In summary, in order to achieve compliance to outcome 2 we must respect a patient’s right to choose whether or not to have a dental procedure, we must assess a person’s competence to make a decision and their ability to understand information relating to their treatment. If a patient is considered incompetent to make a particular decision we must act in line with the Mental Capacity Act Code of Practice to ensure we are supporting the patient and/or their carer to understand and make an informed choice. It is our obligation and duty to provide the patient with as much information as is appropriate and relevant and we must invite and answer any questions the patient may have. Gaining consent is not merely getting a signature on a form it is a process of communicating information to a patient about their needs and your recommendations. You must ensure that consent is volunteered and the patient is fully informed. It is vital that good records are kept on all matters concerning consent to care and treatment, consent should form a part of every single clinical record made. Last but not least monitor consent and regularly review the effectiveness of your procedures.
If you’d like to know more about how Practice Perfection can help you with CQC compliance please get in touch at firstname.lastname@example.org
Welcome to the first edition of the 'Practical Guide to Compliance' series. This series is intended to act as informal guidance to dental teams working toward CQC compliance. The contents of these articles are based on personal opinion and interpretation of the CQC framework and other relevant legislation. Whilst the author has full confidence in the suitability and appropriateness of the information contained within these articles, the information shall not be regarded as fact and those requiring definitive information should consult the relevant governing body.
Outcome 1: Respecting & involving people who use services
What do the regulations say?
"People should be treated with respect, involved in discussions about their care and treatment and able to influence how the service is run".
CQC 'The Essential Standards'
So what does this really mean? Outcome 1 is built around a patient centred approach to care, you need to be seen to be respecting the rights and choices of your patients and involving them in the service you provide. Patients individual needs and choices need to be considered and respected at all levels, this could range from respecting religious beliefs to individual lifestyle choices. Patients should be provided with adequate and relevant information to enable them to make decisions and should be supported to make the right decision for them. Practices should seek patient opinion and actively get them involved in the service on offer.
Now that we understand what is needed, you are probably asking yourself 'so how do we do it'?
Throughout this series you will hear me talking about 'the 4 stages of compliance', this is my method of introducing new ways of working into a team.
The 4 stages are as follows:
Stage 1- Laying the foundations- this involves creating new policies, procedures or working practices and publishing them within your team
Stage 2- Training your team- a written policy or procedure is not worth the paper it is written on if your team don't understand why it exists or what implications it has on their daily work. Training is a fundamental part of compliance and forms the foundation of good practice, your team are your biggest asset and you should continually invest your time and resources to ensure they are the very best that they can be.
Stage 3- Practice makes perfect- So you have a policy, you've done some training but now what? Practice, practice, practice! Everyone within the team needs to have adopted the new policy, procedure or working practice and should be carrying out their duties in line with any new rules or procedures.
Stage 4- Monitor & review- This is perhaps the most important aspect of the process of compliance. It is no good writing policies and training staff if you then go about your business without looking back. Surveys, audits, spot checks all of these things help identify gaps in the system and can highlight areas that need more attention.
The 4 stages of compliance allow you, as a team, to adopt new ways of working and really cement them into your daily life.
So where to start with Outcome 1? Why stage 1 of course!
As with any aspect of compliance there is a set of basic needs that must be met in order to start your journey towards compliance, these could include things like policies, procedures and training.
At the most basic level the following list gives some specific examples of things needed to achieve compliance with outcome 1:
· Equality & Diversity Policy
· Published Fee Guide & Payment Terms
· Data Protection Registration, Policy & Code of Practice
· Confidentiality Policy & Code of Practice
· Patient Information Leaflets
· Team Training
· Patient Survey Template
· Comments Box
· Clinical Record Keeping Policy
· Treatment Planning Policy
· Consent Policy & Procedures (e.g. consent forms)
· Audit Systems to monitor and manage the above
In order to implement any policy or procedure it is imperative to engage the team in the process from the start thus ensuring they adopt the new way of working and ongoing compliance on the issue. This could be done at a team meeting, you could discuss the need for a new policy or procedure and take on board suggestions and comments from the team, this way you are involving them in the project and encouraging them to play an active role in the change.
Once a new policy or procedure has been agreed, it should be written down and made accessible to all. Everyone in the practice must know about the new policy or procedure, they must understand what it is and why it has been put in place.
So your new policy is ready for use, this is the point where most practices fall down. We have a policy, it sits in a folder and we are all vaguely aware of its existence but it has little or no bearing on our day to day work. This is not compliance and having a nicely written out policy will not tick the CQC inspectors box when they come knocking at your door.
For a policy to have any value your team must firstly understand why it is needed, they must understand the implications of working to the policy and they must understand the consequences, for themselves, the practice and most importantly patients, of not complying with it.
To do this is simple, train your team. Use your team meetings to educate your team about a specific policy, make it interactive and fun, if necessary bring in external speakers to get the point across but above all make sure everyone is engaged and knows what it is all about.
Some ideas for monitoring the impact a certain policy or procedure is having on the service you offer could include patient or staff surveys, clinical and administrative audits, spot checks on records and my personal favourite- a team quiz. At your Team Meetings incorporate a 5 minute quiz covering a different compliance topic, the results of this quiz will really help to identify common areas for training and help team members grasp the importance of understanding the topic.
In summary, compliance to outcome 1 can be achieved by having some simple processes in place to ensure that patients are respected, treated fairly and consistently without discrimination. Patients will be actively involved in their care and treatment, given relevant and timely information in relation to their needs and will be supported to make decisions. Patients will be involved in the development and improvement of the service that you offer through the use of feedback and patient opinion. I cannot stress enough the importance of stage 4, monitor and review, this will ensure compliance is not only achieved but more importantly maintained.
If you'd like to know more about how Practice Perfection can help you with CQC compliance please get in touch email@example.com
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