CQC PMS Inspections Citygate Gallowgate Newcastle upon Tyne NE1 4PA Telephone: 03000 616161 Fax: 03000 616171 www.cqc.org.uk Your account number: 1-507418996 Our reference: INS1-528135961 Dr John Elder C/o Ms L Allen, Market Cross Surgery Bourne Road Corby Glen Grantham Lincolnshire NG33 4BB 22 December 2015 Care Quality Commission Health and Social Care Act 2008 Factual accuracy check Location name: Market Cross Surgery Location ID: 1-507418996 Dear Dr Elder, Following our recent inspection of Market Cross Surgery we have drafted the inspection report which is enclosed for your information. This report and GP letter has been sent to the email address of your practice manager as your contact details still have the email address of an old employee. If you have any comments about factual inaccuracies in the report, please submit these together as one response and send them to us by 12 January 2016. You can record your comments in the attached factual accuracy comments log. We would prefer you to send this information to us by email, to this address: [email protected]. If you are unable to do so, please send it by post to the address shown below. Please include your account number (1-507418996) and our reference number (INS1528135961) in your letter or email as it may cause delay if you do not. We will review your comments and amend the report if we consider it appropriate to do so. If we do not accept your comments we will explain why. If we do not receive any comments from you by the date shown above, we will finalise the report and publish it on our website. 1 Your inspection report has been produced using our new approach to regulating and inspecting. For NHS GP practices, part of the new approach will be the publication of ratings for each location, at both key question and population group level. Ratings are awarded on a four-point scale; ‘Outstanding’, ‘Good’; ‘Requires Improvement’, or ‘Inadequate’. The table below shows the ratings this location has been awarded: Safe Effective Caring Responsive Well-led Overall population group Older people Requires Improvement Good Good Good Requires Improvement Requires Improvement People with long term conditions Requires Improvement Good Good Good Requires Improvement Requires Improvement Requires Improvement Good Good Good Requires Improvement Requires Improvement Requires Improvement Good Good Good Requires Improvement Requires Improvement Requires Improvement Good Good Good Requires Improvement Requires Improvement Requires Improvement Good Good Good Requires Improvement Requires Improvement Overall domain Requires Improvement Good Good Good Requires Improvement Overall location Requires Improvement Families, children and young people Working age people and the recently retired People in vulnerable circumstances People experiencing poor mental health We ensure a fair process for setting ratings and will be transparent in investigating any concerns. We will explain how and when you can request a review of your ratings in the letter we send with the final report. You can only request a review of your ratings if you think we have not followed our published process for awarding ratings. If you have any questions about this letter, you can contact our National Customer Service Centre using the details below: 2 Telephone: 03000 616161 Email: [email protected] Write to: CQC PMS Inspections Citygate Gallowgate Newcastle upon Tyne NE1 4PA Yours sincerely, Carolyn Fairbrother CQC Inspector Enclosed: Draft report Factual accuracy comment log 3 Factual accuracy comments log for the draft report Please fill in all parts of this form and return by email to: [email protected], or by post to: CQC PMS Inspections, Citygate, Gallowgate, Newcastle upon Tyne, NE1 4PA Account Number: Our reference: Location name: Location address: 1-507418996 INS1-528135961 Market Cross Surgery Bourne Road, Corby Glen, Grantham, Lincolnshire, NG33 4BB Page Heading e.g. Is the number e.g. Pg 10 Service Safe? Suggested changes with explanation e.g. change last sentence from 10 staff to 15 staff Pg 3 Bullet point 2 – 1st paragraph The 3 sites selected were deemed appropriate because of their secure locations; the guidance produced by the DDA regarding remote medicine pick up points has been followed – in particular no scheduled or controlled drugs can be delivered to these points & no cash transactions take place Summary of findings Page 11 Page 16 CQC decision CQC comments e.g. explanation of decision or X Thank you for your feedback which we have considered. X We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. No risk assessments had been carried out for these locations. Pg 3 Bullet point 3 – 1st paragraph Page 11 Page 17 Summary of findings These are performed regularly and all emergency drugs & equipment is in full working order. Drugs are appropriate to a primary care setting and in date. The protocol has been revised and issues pertaining to checks not always being carried out when staff are on leave addressed X The report has been amended to say ‘three medicine pick up points’. Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. On the day of the inspections there was found to gaps in the checking of emergency 4 drugs and equipment. Pg 3 Bullet point 4 Summary of findings – should make improvements Page 11 Mitigating risks & actions – what exactly is meant by this? The business continuity plan provides the Practice with what is required for an extreme event – it is a comprehensive & practical informative document produced following standard examples X We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. Within a business plan there needs to be a risk assessment which looks at the areas identified in the plan, for example, loss of power supply, and decide what level of risk that would be. Page 17 Pg 3 Bullet point 5 Page 11 Pg 3 Bullet point 6 Page 11 Summary of findings – should make improvements Summary of findings – should make improvements Ensure SOPs for Dispensary include a competency section – staff competencies are assessed as part of our annual DSQS submission. Discussions already taken place that the competencies will form part of the appraisal process for Dispensary staff. Fridge temperature recordings are and always have been made in accordance with the manufacturer’s instructions for Thank you for your feedback which we have considered. X In your action plan post inspection you identify that a Risk rating(mitigating risks) will be added to the business continuity plan. Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. X As discussed with the dispensary manager each standard operating procedure requires a section that states what the competency of staff should be for that required SOP. Thank you for your feedback which we have considered. 5 the various fridges; following concerns raised about the accuracy of built in fridge temperature monitors additional in fridge monitoring USB devices have been purchased & have been in operation for some time before the visit Page 16 Pg 3 Bullet point 7 Summary of findings – should make improvements Page 11 Page 17 Pg 3 Bullet point 8 Pg 3 Bullet point 9 (continued overleaf) Summary of findings – should make improvements Summary of findings – should make improvements We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. On the day of the inspection we saw records that showed that the minor operations fridge had not been reset on a daily basis First aid equipment – the practice is a provider of a minor injury service – a full comprehensive stock of all first aid equipment is kept within the treatment room; it is unfortunate that an old kit was found in the back of a cupboard on the day of the inspection – this is not in use nor has it been. The items within designated “out of date” were not perishable or sterile. Mea culpa – we should have thrown it out X Minor surgery & IUCD audits are performed quarterly for payment & quality purposes. They were not viewed nor were they asked to be viewed. The Practice was a founder site for the RCGP/HSCIC Minor Surgery audit – involvement in this project was temporarily suspended during 2015 due to functionality issues with the HSCIC Website X Notes summarisation – the Practice has fully summarised records for 95% of all patients – all incoming records are X Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. On the day of the inspection out of date contents were found to have expired in 2009. Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. I have checked the inspection notes and we were not shown aa minor surgery or IUCD audit. We were told that the lead GP had not completed one during 2015. Thank you for your feedback which we have considered. 6 summarised as quickly as possible - the Practice was an early adopter of GP2GP transfer – in addition to reviewing all incoming electronic notes manual updating & checking is performed. There is no significant back log of notes needing summarising & we cannot accept this criticism. The checking of paper records against incoming electronic records is a lengthy and time consuming process but is undertaken in a systematic way Pg 3 Bullet point 10 Page 12 Pg 3 Bullet point 12 & Pg 5 Bullet point 5 Summary of Evidence of NMC registration findings – for all nurses was provided on should make the inspection day improvements Summary of findings – should make improvements Responsive to needs Page 12 Page 21 Pg 4 Bullet point 3 Page 2 Page 3 Page 11 Safe Summary Learning from complaints – In addition to complaints being discussed at practice meetings or with individual clinicians an annual review of complaints meeting is held (as per old QOF) with summary of complaints & learning points. Evidence of our 2014-15 complaints review was emailed to Carolyn Fairbrother on 25.11.2015 shows wording learning points shared with relevant staff on front cover sheet of review document All clinical staff have completed appropriate level 3 training or are booked on the appropriate course (new Practice nurse was already booked on level 3 child protection for 2016 at the time of the inspection – her training We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. On the day of the inspection we were told by staff that there was a backlog of approximately 50 sets of patient records going back to January 2015. At our feedback session you identified that a member of staff would be given more hours to ensure that the summarisation of notes was brought up to date. Thank you for your feedback which we have considered. The report has been amended. Thank you for your feedback which we have considered. The report has been amended. Thank you for your feedback which we have considered. The report has been amended. 7 Pg 4 Bullet point 4 Safe Summary records are locked by her previous NHS trust but we are assured she has completed level 3 adult safeguarding) General safety issues – see P16 comments X Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. Pg 5 Bullet point 2 Pg 5 Responsive to people’s needs Well Led On reviewing the figures quoted throughout our draft report for the July 2015 survey against the online GP Patient Survey results we have found the percentages do vary. Please could these be rechecked to ensure the correct percentages are shown in our published report Completely contradictory statements – High standards are promoted & owned by practice staff with high levels of constructive engagement & teams working together across all roles yet you state there is limited framework to support the delivery of good quality care. This is unacceptable & unjustified. Elsewhere we are complemented on audit & outstanding levels of patient satisfaction & results – risks are monitored, patients reviewed in detail at weekly & quarterly meetings involving multidisciplinary teams – X In your action plan post inspection you identify an estimated completion date of 31January 2016 Thank you for your feedback which we have considered. We will not amend the report. X All the data on pages 2,5,11,20 and 21of the draft report had been rechecked against the July 2015 national patient survey and is all correct. Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. On the day of the inspection and within your action plan sent after the inspection you have identified that the practice had a 8 considerable evidence of this was provided & discussed at length yet is not reflected in the report. MDT meetings utilise actual patient computerised records – additions & annotations are made during meetings or shortly after where little of significance is decided. limited governance framework in place to support the delivery of the strategy and good quality care. For example, systems for assessing and monitoring risks and the quality of the service provision. The practice completely refutes the suggestion that we are anything other than well led – the practice has grown & flourished over the past 20 years in the face of significant competition; the list has risen for 800 to 4300; staff turnover is minimal, moral was high despite the current NHS situation and we have been able to move to purpose built premises at significant personal cost to the GP principal; the practice is an active provider of all enhanced services including services to non-registered patients such as advanced Family planning including IUCDs & Sub dermal implants & has historically provided HPV vaccination & INR services for other local Practices who chose not to provide for their patients; it is a major employer in the community & provides a vast range of services beyond that normally seen in primary care. The Practice has provided the County with a near patient testing Enhanced service for community DVT management and is currently piloting a teledermoscopy service; The practice championed the cause of Parkinson’s disease & was instrumental in the establishment of the Parkinson’s nurse service in South Lincolnshire. The 9 Practice was instrumental in the CCG promoting screening for AF in line with national guidance & the provision of a cardiology up-skilling course for local GPs. In addition, we also have been able to provide in house Physiotherapy & Ultrasound services We will accept that formal appraisal had not occurred for all staff in the past 12 months yet despite this comprehensive additional postgraduate training & career development has been undertaken by all clinical staff. Pg 7 Older people Summary of findings Requires improvement yet all points are good or excellent except for “safety & Well led” which we do not accept X X Thank you for your feedback which we have considered. We will not amend the report because on the inspection day and in this FAC you have agreed that this is correct.. Thank you for your feedback which we have considered. We will not amend the report because the paragraph in this section is correct. Due to the overall rating being Requires Improvement along with Safe and Well-led domain - Page 7 Long-term Conditions Summary of findings Requires improvement yet all points are way above local or national levels – should be Outstanding X ‘The concerns which led to these ratings apply to everyone using the practice, including this population group.’ Thank you for your feedback which we have considered. We will not amend the 10 report because the paragraph in this section is correct. Due to the overall rating being Requires Improvement along with Safe and Well-led domain - Pg 8 Families, children & young people Pg 8 Working age people Summary of findings Summary of findings All points were good with above national average figures & high levels of immunisation uptake & examples of multidisciplinary working with midwives & Health visitors yet again graded as Requires improvement All points extremely positive yet gain graded as requiring improvement X ‘The concerns which led to these ratings apply to everyone using the practice, including this population group.’ Thank you for your feedback which we have considered. We will not amend the report because the paragraph in this section is correct. Due to the overall rating being Requires Improvement along with Safe and Well-led domain - X ‘The concerns which led to these ratings apply to everyone using the practice, including this population group.’ Thank you for your feedback which we have considered. We will not amend the report because the paragraph in this section is correct. Due to the overall rating being Requires Improvement along with Safe and Well-led domain ‘The concerns which led to these ratings apply to everyone using the practice, including this population group.’ 11 Pg 9 Vulnerable groups Summary of findings Again glowing reports yet rated as requiring improvement X Thank you for your feedback which we have considered. We will not amend the report because the paragraph in this section is correct. Due to the overall rating being Requires Improvement along with Safe and Well-led domain - Pg 9 Poor mental health Pg 11 Bullet point 1 Summary of findings Areas for improvement - Must take action As before significantly above average statistics & reports – not mentioned in the report the Practice is involved with the local dementia service & plans to provide facilities for an in house CPN run dementia assessment service in conjunction with the CCG – yet again “requires improvement” We accept that significant event meetings have been less frequent in the past year than previously however evidence was provided of a true significant event for which a separate meeting was held, independent advisor invited to attend & from which a revision to a dispensary SOP was derived. Significant event meetings need to be significant X ‘The concerns which led to these ratings apply to everyone using the practice, including this population group.’ Thank you for your feedback which we have considered. We will not amend the report because the paragraph in this section is correct. Due to the overall rating being Requires Improvement along with Safe and Well-led domain - X ‘The concerns which led to these ratings apply to everyone using the practice, including this population group.’ Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. X The practice did not 12 otherwise they merge into normal practice business & the “significance” is lost; all staff are & have been involved in the past & learning is cascaded where appropriate both internally & externally. We have been regular contributors to clinical governance reports particularly relating to poor INR management in hospital and on discharge. All clinical staff are trained to level 3 Adult safeguarding; The new practice nurse has been enrolled (before CQC visit) on level 3 child protection during 2016. All clinicians are aware of their individual responsibility to maintain level 3 training & evidence of this was provided on the inspection day These are all repeated earlier in the document Pg 11 Bullet point 2 Areas for improvement – Must take action Pages 11 & 12 Summary of findings Pg 13 Paragraph 3 Background to Practice Manager is not a MCS Partner Pg 13 Paragraph 3 Page 13 Paragraph 3 Background to We have 3 Practice Nurses MCS Background to We have 5 Dispensers MCS Page 14 Detailed penultimate Findings paragraph line 2 Page 15 Bullet point Safe You spoke to 3 Practices Nurses on the inspection day Please provide us with details of the two significant events have a system in place to ensure significant events and near misses were recorded correctly, investigated and any learning cascaded to staff As page 7 of this FAC this report has been amended See comments in early boxes Thank you for your feedback which we have considered. The report has been amended. Thank you for your feedback which we have considered. The report has been amended. Thank you for your feedback which we have considered. The report has been amended. Thank you for your feedback which we have considered. X The report has been amended. Thank you for your feedback which we have 13 1 which were not recorded on the correct form considered. We will not amend bullet point 2 of the report because the record of our inspection shows that this paragraph is factually accurate. On checking the inspection notes there were a number of incidents not on the correct form:for example, Sample given wrong name on label trace – system down Patient given path links form with wrong patient name on it. Page 15 Bullet point 2 Safe - our findings Significant events – see above but also statement is untrue – A full annual compilation of significant events had not been prepared since 2014 – these are undertaken annually previously for submission with QOF but latterly as part of GP appraisal & annual returns to NHSE; therefore the 2015 summary of SE meetings is now due to be produced – SE meeting had taken place in spring of 2015 & another meeting was due in the late summer but had been delayed. If there were examples of incidents of a significant level that were identified to you but had not been reported as such then please expand & clarify. Not all events are discussed in a significant event meeting – particularly if they are of a disciplinary nature. Your clarification of this would be appreciated as it was not raised at the time of the visit. Thank you for your feedback which we have considered. The report has been amended. The sentence .’During our inspection, we requested details of annual reviews of significant events. We were told that these had not been carried out since 2014’ has been removed. And we have added ‘We found that the practice had not undertaken an exercise to identify any themes or trends’ 14 Page 16 Bullet point 6 Page 16 Bullet point 8 Page 16 Bullet point 9 Safe Safe Safe Recruitment policies – all appropriate registration & qualification checks were in place for employed professionals including DBS checks where appropriate. The Practice will consider moving to DBS checks on all staff (including longstanding members of staff who have been employed with the practice for a number of years) given their multiple roles within the organisation, The current regulations are adhered to X Thank you for your feedback which we have considered. We will not amend bullet point 6 of the report because the record of our inspection shows that this paragraph is factually accurate. On checking the inspection notes gaps were found in the recruitment checks prior to employment. H&S Risk Assessment June 2015 – confirmation by e-mail to Carolyn Fairbrother post inspection 10.12.15 confirming actions were ongoing; as demonstrated with post inspection evidence an action plan for anything outstanding is in place demonstrating our commitment to ongoing H&S improvements and monitoring X We have an arrangement in place with Churches Fire for regular checks on our fire panel, emergency lighting and fire extinguishers. There is a log book and folder in the Practice Managers office where this information is recorded. A member of our Reception Team tests the fire alarm and records in the book contained in the above folder. Although fire drills & evacuations have historically been recorded in the surgery day book – these are now X In your action plan post inspection you identify that a recruitment checklist will be added to the policy for all new staff with immediate effect. Thank you for your feedback which we have considered. We will not amend bullet point 8 of the report because the record of our inspection shows that this paragraph is factually accurate. Thank you for your feedback which we have considered. We will not amend bullet point 9 in regard to the fire risk assessment because the record of our inspection shows that this paragraph is factually accurate In your action plan post 15 Page 16 Bullet point 11 Page 16 Bullet point 13 Safe Safe recorded in the above log book. The actions for the 2012 fire risk assessment were carried out but there has not been a further risk assessment to date. In addition to the checks already being carried out by Churches an Annual Fire Risk Assessment will take place going forward; Louise Allen & Sarah Rutherford are booked on Fire Warden Training in Feb 2016 It is incorrect that none of the actions from the legionella action plan had been carried out at the time of the inspection. Regular water temperature checks (monthly) take place and the log was seen on the inspection day. Flushing of identified infrequently used taps where appropriate would take place and be logged; in fact the taps identified in the last report are in frequent use and this is one of many inaccuracies within the Legionella report. Flow temperature monitors are already fitted to the pipes providing hot water distribution & all pipe work is appropriately colour coded with directional markings. The taps in consulting & clinical rooms are a mixer type with temperature limiting valves not as described in the report. We are concerned that the Legionella report is factually incorrect & we will be using an alternative engineering firm for the next report. There are no key outstanding areas of work All staff undergo annual basic life support training inspection you identify that you were uncertain if the action points were completed from the two previous reports. X Thank you for your feedback which we have considered. We will not amend bullet point 11 in regard to the legionella risk assessment because the record of our inspection shows that this paragraph is factually accurate In your action plan post inspection you identify that action points to be completed by 31/3/16.. Thank you for your feedback which we have considered. The report has been amended. 16 Page 17 Bullet point 1 Safe Post inspection evidence in the form of letter was sent to Carolyn Fairbrother justifying why we do not have paediatric defibrillator pads X Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. A letter was received post inspection. Further email sent by inspector asked the practice to clarify if a risk assessment had been carried out in light of the decision made re paediatric defibrillator pads. No further information was received. Page 17 Bullet point 3 Safe The protocol stated weekly although this had been relaxed to fortnightly. There were still omissions & this has been immediately addressed & designated nurse procedures strengthened including deputies & a protocol refresh. All emergency drugs are recorded on an excel spreadsheet with their expiry dates linked to colour coding (conditional formatting – turn red when expired) Drugs are re-ordered in advance of expiry EXCEPT when they are unavailable in which case they are retained within the extension beyond expiry date as suggested by manufacturer (emergency injectable drugs are often unavailable and drug shelf life has to be extended) X Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. On the day of the inspections there was found to gaps in the checking of emergency drugs and equipment. In your action plan you have documented that the practice will ensure system in place for emergency equipment checks in the absence of Christine Day. With immediate effect. 17 Page 17 Bullet point 5 Page 19 Bullet point 2 Safe Effective Business continuity plan – all key risks identified; no recommendation or requirement for risks to be “rated” – the document is a working document for use in times of crisis Please provide details of staff members who did not have an appraisal record on their personnel file X Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. Within a business plan there needs to be a risk assessment which looks at the areas identified in the plan, for example, loss of power supply, and decide what level of risk that would be. X In your action plan post inspection you identify that a Risk rating(mitigating risks) will be added to the business continuity plan. Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. For example:Kirstie Simmons Christine Day Page 19 Bullet point 3 Effective Please provide details of staff who were missing from the training matrix X Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually 18 accurate. For example:Dispensary Staff Page 19 Bullet point 4 Effective Training all staff completed the 2 day mandatory Pathway training including BLS & child protection yet elsewhere you suggest this is not the case. All staff completed this training for the past 2 years. Thank you for your feedback which we have considered. Page 16 of the report has been amended. Pages 20 & 21 Caring In comparison with reports of practices elsewhere in the UK these results should be graded as outstanding X Page 21 final Bullet point Responsive If there were themes or trends shown in complaints received these would be highlighted, discussed and highlighted at our annual complaints meeting X Thank you for your feedback which has been noted. However the rating remains the same. Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. There was no evidence on the day of the inspection to suggest themes and trends were considered. Page 22 Well Led See P5 above – your comments however “clear staff structure, clear leadership structure in place, open culture within the practice, confident to raise issues, supported, respected valued; all involved with development & opportunities to improve the service provided X Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that the paragraphs on page 5 and page 22 are factually accurate. On the day of the inspection and within 19 your action plan sent after the inspection you have identified that the practice had a limited governance framework in place to support the delivery of the strategy and good quality care. For example, systems for assessing and monitoring risks and the quality of the service provision. Page 22 Bullet point 7 Governance Louise Allen completed Level 3 H&S Management Course in July 2015 which will enable further progression of risk assessments required. This investment also demonstrates that the practice is committed to our H&S obligations. H&S assessments including Legionella & Fire – see notes above but Legionella all points addressed & compliant – Fire risk assessment all points addressed & compliant from 2012 – regular fire system inspections & reporting (Include additional rows if required) X Completed by (name(s)) Dr John Elder & Louise Allen Position(s) Senior Partner & Practice Manager Date 08.01.2016 Thank you for your feedback which we have considered. We will not amend the report because the record of our inspection shows that this paragraph is factually accurate. In your action plan post inspection you identify an estimated completion date of 31January 2016. 20
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