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Welcome to the fourth 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 4 Care and welfare of people who use the service This outcome is centred around ensuring that you are delivering safe and appropriate care to your patients. What do the regulations say? "People should get safe and appropriate care that meets their needs and supports their rights". - CQC Essential Standards Compliance with this outcome will be achieved through having systems and procedures in place for managing patient care. You will need to demonstrate your process for assessing patients prior to treatment, this could be in the form of a written procedure for examinations/assessments, it should detail what the assessment entails, how you involve the patient in the process and how you identify and take into consideration their individual needs and choices. Every patient should be given a written care plan detailing their individual needs and choices, the detail included within this care plan will depend upon the complexity and nature of their treatment needs however it essential all patients are given a full details of all care and treatment options appropriate to them. The treatment planning process needs to take into consideration a patients indivdual needs and preferences and patient involvement here is key. A treatment planning policy will serve as a means for setting the required standard of treatment planning in your practice. There should be provision within your treatment planning processes for dealing with changes in treatment needs/wishes and how patients are involved in this process. The operation and monitoring of an effective treatment planning policy will not only serve as evidence of compliance to this CQC outcome but will also count towards compliance with the outcomes we have already covered in this series (1, 2 and 3). Educating your patients about their treatment needs is paramount you must make sure that you have made every effort to support their decisions regarding treatment, this could include discussions, providing further information and resources or even offering alternative option where appropriate. It is important that patients are made aware of the consequences of foregoing a particular treatment. All care provided should be done so in line with the appropriate clinical guidance for example demonstrating your compliance with NICE recall guidelines would be considered evidence of this. This can be done by having a Recall policy detailing the criteria for recall selection and subsequent recall interval audit to monitor the operation of this policy. All assessments and treatment planning processes should be operated in line with your practices equality and diversity policy to ensure people are protected from unlawful discrimination. Having the above processes in place will reduce the risk of patients receiving unsafe or inappropriate treatment. By carrying out a detailed assessment you will be obtaining all the relevant information to ensure your treatment recommendations are the most appropriate course of action to address the patients individual needs. This outcome also requires practices to plan for any foreseeable emergency situations. To do so you must be aware of what risks exist in your practice, this will be covered in much greater detail in Outcomes 8-10 but in brief you will need to: · Carry out risk assessments and reflect on the findings · Show evidence that you have learned from adverse events, incidents, errors and near misses · Evidence that you operate a being open policy with regards to patient care, if there an error, incident or adverse event has occurred in the course of patient care that has caused or may cause harm, you should offer a full explanation and the appropriate apology. · Take notice and actions in relation to relevant safety alerts When planning for foreseeable emergencies it is necessary to think about what could go wrong and how can we minimise the effects of such emergency. For example we all undertake annual medical emergency training (or at least I hope everyone does) and we put into practice what we learn. We keep the appropriate emergency drugs and equipment and know how to identify different conditions and how to provide immediate and potentially life saving treatment before medical help arrives, this is an example of planning for a foreseeable emergency. Other types of foreseeable emergencies might include fire or major equipment failure, things that may put your surgery/practice out of commission for some time. How do you ensure patients are provided with safe care and treatment and continuity of care during this time? A detailed business continuity plan will help you put plans in place for these situations as well as many others and it is a necessity to achieve full compliance. Once you have a plan it is essential everyone knows about it and what role they play. Of course the key to all of the above is implementation, team training, monitoring and review. Make sure your team understand all your policies and procedures and are knowledgeable about what their individual role in each process is. Set up systems for monitoring everything that you put in place for example a record keeping audit will help highlight the effectiveness of a treatment planning policy. It is important to review the effectiveness of your policies and procedures to make sure you are using the most up to date methods and guidance. You will now start to see that many of the CQC outcomes are inter-linked in many ways and evidence you have started collecting for earlier outcomes will also serve as evidence for this and others too. If you’d like to know more about how Practice Perfection can help you with CQC compliance please get in touch at [email protected] or call 07703627873
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Welcome to the third 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 3- Fees This outcome is all about how you charge fees for your services. Although not one of the core 16 outcomes it is considered relevant to dentistry and it is important that you comply with it. What do the regulations say? People who pay for a service should know how much they have to pay, when and how to pay it, and what they will get for the amount paid. -CQC Essential Standards This should be one of the easier outcomes to comply with as most practices have been producing fee guides, written treatment plans and cost estimates for some time. However this guidance encourages you to take this a little further to comply with this outcome. The first step towards complying with this outcome is to have a published fee guide and payment terms. This applies to both NHS and Private practices, if your patients are expected to pay for all or part of their treatment they need to know how much they will be required to pay before they go ahead with anything- this includes examinations, consultations and diagnostic tests. Your fee guide should be comprehensive covering all the services and treatments that you offer, where it is not possible to provide a fixed cost for example a filling is usually priced by surface and in this instance you need to provide a fee scale for example £75 - £125. Your payment terms should clearly state how and when the patient will be expected to pay. You should state what methods of payment are accepted for example cash, cheque and credit debit cards. If you offer finance or payment plans then some mention should be made to these. the payment terms should also make clear the patients obligations for example fees are due on completion of treatment or similar. It needs to be made clear when you expect the patient to pay your fees. Payment terms should also clearly state the consequences of late or non payment of fees agreed. You should also include details of how a patient would cancel their agreement for treatment once they had started the treatment and what proportion of fees may be payable. When you are prescribing treatment you must provide the patient with details of the full cost in writing, this can be done by supplying patients with a written estimate detailing the cost of each treatment recommended. When providing estimates it is important to be as clear and transparent as possible, there is no requirement at the moment to itemise the individual fee components of treatment but in some cases this would be advisable for example when providing an estimate for Endodontic Treatment, if you are applying a surcharge to cover the cost of single use files this should be stated. For more complex or high valued treatment it would be advisable to provide a written treatment plan which is a little more detailed than a standard estimate. Within this you could include your recommendations, associated fees and also include a section about any additional fees that may become necessary. Within any estimates or treatment plans you must be explicitly clear of what is and is not included in the fee quoted for example if you are carry out a root canal treatment and you will be charging a fee on top for the filling this must be made clear, if you also plan to crown the root treated tooth months later the patient should be informed of the cost and an given an idea of when they should expect to pay the additional charges. It is important to give costs for each stage of treatment and when each payment is due as the patient may wish to discontinue their treatment with you at any time and you need to make sure that they are clear about what costs are incurred up to that point. Once you have determined the treatment needs of a patient and provided them with details of their treatment plan and costs it is vital they are given time to consider their options. Patients must freely agree to go ahead with treatment and it is important that they sign a copy of any estimates or treatment plans agreed and they should also be given a final copy of this signed document. You must ensure that there is someone available to discuss the terms of any treatment plan with the patient should they request it. This person should have enough knowledge to answer any questions the patient may have. Once a patient has entered into treatment and has agreed the fees you are required to: · Provide a statement of account upon request · Offer a receipt for all payments received · Provide written details of any change in cost due to unexpected changes in the treatment plan In order to implement all of the above into practice it is advisable to incorporate fees into your consent procedures. This will allow you to make sure that agreement to fees is being obtained and recorded effectively and provides you with an audit trail for monitoring compliance. Another way you can monitor compliance to this outcome is through a question in your patient survey to find out whether patients felt fully informed of the fees relating to their treatment. Whilst this outcome is relatively simple in its requirements I believe it will evolve into something more in years to come. The Office of Fair Trading launched a market study into Dental fees in September 2011 and I see this report highlighting the large pricing inconsistencies between different practices, lack of clarity into what the fee covers and quite possibly the need for a more transparent approach to pricing. OFT plans to complete this report by March 2012 so we'll soon hear about their findings. If you’d like to know more about how Practice Perfection can help you with CQC compliance please get in touch at [email protected] or call 07703627873 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 [email protected] 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 protected] The way a patient perceives your service could make or break the success of your business.
The patient experience is one of the most (if not THE most) important aspect of what your practice has to offer. The patient experience covers every angle of a patients journey through your practice, from the moment they find out about you, how their initial enquiry is handled, their first and subsequent visits and every piece of communication that they receive from you. We are in a 'service' industry, people are paying for a service and they will expect a good one. So how do you measure and evaluate the service that your patients are receiving? Are your marketing strategies making you visible to potential patients and putting you ahead of the competition? Are your team handling new patient enquiries effectively? Are you communicating effectively with your customers? The most important question is are you providing a truly EXCEPTIONAL service? There is no doubt that we are facing difficult times ahead in this struggling economy, with less disposable income patients are prioritising their spending and investing their money in a trusted, consistent service. It will be survival of the fittest and those practices that are custom focused and constantly striving to provide an exceptional service will prosper and grow. What would you say if I told you it was possible to evaluate your Patient Experience through the eyes of a patient? Practice Perfections 'Patient Experience Evaluation' allows you to see your service through the patients eyes. We will send a 'mystery patient' to assess your service and will provide you with a detailed report to highlight your strengths and weaknesses in specific areas. Our Patient Experience Evaluations are conducted by experienced dental professionals, people who know how it should be done. Our report comes complete with recommendations packed full of proven strategies for success. In conjunction with our Patient Experience Evaluations we offer the added option of bespoke team and individual training to help you implement and train your team on our recommendations. With the obligation to compliance in mind, we have designed our evaluations and reports to act as evidence towards CQC Outcome 1- 'Respecting & Involving people who uses the service'. We offer a range of options from a simple telephone evaluation to a full patient experience evaluation. Prices start from as little as £49.99 and packages can be tailored to suit your needs. Visit www.practice-perfection.co.uk or email [email protected] for more information. As Dentistry is becomes increasing commercial we are seeing an ever increasing amount of advertising and publicity relating to dental services. Equally, as competition increases and as patients are doing more ‘shopping around’ it is becoming necessary for practices to increase awareness of their brand.
As an industry bound by ethics there are several factors that should influence the nature and content of any advertisements, promotions or provision of information. With effect from 1st March 2012 the General Dental Council have introduced some new rules for dental business’ to follow ‘Principles of Ethical Advertising’. This blog post will introduce you to the requirements of this document and will help you make a start to make sure you are playing by the rules. This guidance doesn't just apply to dentists, it covers all GDC registrants so if you are on the GDC register or producing information on behalf of a registrant read on... As a registrant you have an over-riding responsibility to ensure that any advertisements, promotional items and information sources containing your name are correct, including your GDC registration number. All advertising and sources of information should use accurate information that is updated regularly, using clear and simple language avoiding dental terminology that the general public may not understand. Avoid making unsubstantiated claims, many practices out there make claims like ‘pain free dentistry’ how do you substantiate this statement? What evidence do you have to back up this claim? A simple survey of a patient’s perception of pain during treatment could give you this evidence but it must be collected regularly and consistently. Using statements like ‘we’ll give you the perfect smile’ without qualification, could be misleading and considered ambiguous. Achieving the perfect smile is possible in many different ways depending upon individual needs and for some people it may not be possible and imperfect compromises have to be made. Avoid claims or statements intended or likely to create unjustified expectations. If your marketing promotes a fantastic patient experience, this must be delivered to each and every patient. If you offer services that promise a quick result for example ‘Straight Teeth in Weeks’, it is important within your advertising to mention that these treatments are not suitable for everyone and in some cases limited results will be seen. If the patient isn’t told this from the get go you have given them an unrealistic expectation. Be clear about the nature of your service- is it NHS or Private or a mixture of both, be clear about your offering and make sure patients are not being mislead about what type of treatment they can expect to receive and the fees that might apply. Many clinicians are now offering services that do not fall under the remit of traditional dentistry such as facial aesthetics or hygienists and therapists offering tooth whitening. When promoting these services and performing treatments that did not form part of your primary training you must be able to demonstrate that you have undertaken the necessary training in this area to achieve competence. The guidance also lays out some rules for Dental websites. It is written in line with the Code of Ethics for Dentists in the EU for Electronic Commerce which covers the content of dental websites. To view the guidance document click here. In order to follow the new guideline rules on websites it is likely going to be necessary for you to modify your current website to include these additional requirements. You will also need to be able to make regular updates to reflect any changes in personnel, it is specified in the Ethics for Dentists in the EU document that a registrant who leaves the practice should be removed within 1 month. Your website, as with any other promotional material, must not provide a comparison between the skills and qualifications of yourself and any other dental professional and should not suggest your skills and qualifications are superior to anyone else. The term ‘specialist’ has been a real bone of contention for the GDC in recent years due numerous registrants referring to themselves ‘a specialist in...’ or a practice calling itself a ‘specialist practice’ when in fact they are not specialists. In order to refer to yourself as a ‘specialist’ you must be on one of the GDC’s 13 specialist registers. If you are not, it is not acceptable to refer to yourself as a specialist. Instead you can say ‘special interest in’ or ‘experienced in’ or ‘practice limited to’, the bottom line is that by incorrectly using the term specialist you are misleading the public into thinking you are something that you are not. The above does not only apply to dentists, there are currently no specialist lists for DCP’s and on this basis the term must be avoided for example ‘specialist denture technician’ or ‘specialist implant nurse’. Regardless of what level of further qualification you have gained, unless you are a registered specialist you simply cannot refer to yourself as one, to do so would be viewed as misleading. Gaining an honorary degree or professional fellowships and memberships are often prestigious achievements however listing letters after your name in recognition of these achievements for marketing purposes can be very misleading for patients. Patients do not always understand the meaning of these letters and they may view them as a reflection of additional skills and academic qualifications which may not be the case. Keeping things simple and restricting the use of letters after your name to those that are meaningful to the general public will ensure you are working in line with these rules. In summary, with any advertising or promotional information you produce for patients you must keep ethics in mind at all times. You must produce information that is truthful, honest, easy to understand and promotes the best interests of the patient. Compliance is a word we are all to familiar with, thanks to the introduction of HTM01-05 and the CQC outcomes.
As an industry that has been relatively unregulated from a management perspective it has come as quite a shock to many practices to find out just how much work is required. We are almost a year down the line after CQC registration and many practices are still struggling to cope with the additional workload that has been forced upon us not to mention the added burden of costs associated with compliance. It sounds like a pretty bleak picture doesn't it? Actually compliance is a great thing! You're probably reading this thinking I am mad but let me explain... For many years dental practices have been run as 'dental practices' instead of businesses, little awareness or emphasis on business focus has been evident and difficult lessons have been learned. Compliance forces us to become more business focused, customer service, patient involvement, team development all things that will ultimately improve our businesses. Financial management is another key area that has all to often been overlooked in dentistry and difficult lessons have been learned. With the added cost of compliance we are all forced to sit up and take notice of our numbers. With registration fees, equipment testing and validation, team development, the list is endless and costs could soon spiral out of control. In order to achieve compliance in an efficient and cost effective manner it's important to implement systems that work, don't let compliance give you a headache, let us show you how to set up and run the management systems that work! For more information visit www.practice-perfection.co.uk or contact us at info@practice-perfection.co.uk |
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