2 November 2017
During a routine inspection
We carried out an announced comprehensive inspection on 2 November 2017 to ask the service the following key questions; Are services safe, effective, caring, responsive and well-led?
Our findings were:
Are services safe?
We found that this service was not providing safe care in accordance with the relevant regulations.
Are services effective?
We found that this service was providing effective care in accordance with the relevant regulations.
Are services caring?
We found that this service was providing caring services in accordance with the relevant regulations
Are services responsive?
We found that this service was providing responsive care in accordance with the relevant regulations.
Are services well-led?
We found that this service was not providing well-led care in accordance with the relevant regulations.
Background
Knightsbridge Doctors - Bentinck Mansions (trading under the name of Visa Medicals) is a private facility providing ‘third party’ medical examinations to individuals who require medicals for visa applications to visit the United States of America and Canada. The services are provided from a location at 4 Bentinck Mansions, London, W1U 2ER.
The provider employs a practice manager, three nurses, three radiographers and three reception/administrative staff. There are 10 immigration doctors and one lead immigration doctor who work under practising privileges (the granting of practising privileges is a well-established process within independent healthcare whereby a medical practitioner is granted permission to work in an independent hospital or clinic, in independent private practice, or within the provision of community services).
Services provided as part of a visa medical include chest X-rays; blood pressure checks, blood sampling and assessment of vaccination status and provision of vaccinations for immigration purposes. The practice is open 8.30am to 5pm Monday to Friday and 9am to 1pm on occasional Saturdays. Patients are asked to call to book an appointment by telephone between 9am and 5pm. They are invited to state their preferred appointment times (at least five working days before their visa interview date for applicants for the USA) and are usually able to get an appointment of their choice within two working days. Visa medicals usually last an hour and a half with the first appointment starting at 8.50am and the last at 3.30pm.
The provider is registered with the Care Quality Commission (CQC) to carry on at the practice location, Bentinck Mansions, the regulated activities of Treatment of Disease Disorder or Injury and Diagnostic & Screening Procedures. The provider, Knightsbridge Doctors, has applied to remove Bentinck Mansions as a location as it is now trading as a separate company, Visa Medicals. After the inspection we informed the provider that in the provision of services as described to us, Visa Medicals was carrying on the regulated activities of Treatment of Disease Disorder or Injury and Diagnostic & Screening Procedures. We therefore advised Visa Medicals that they were required to apply to register with the CQC as a new provider and location alongside Knightsbridge Doctors’ application to remove Bentinck Mansions as a registered location. At the time of writing no new provider and location application had been made. However, the provider has been in contact with our Registration team about progressing this.
The currently registered manager of Knightsbridge Doctors - Bentinck Mansions, resigned from the practice in 2016. We were told that the current practice manager of Visa Medicals would be applying for registration as the registered manager of Visa Medicals. This would need to be linked to the new provider and location application. A registered manager is a person who is registered with the CQC to manage the service. Like registered providers, they are ‘registered persons’. Registered persons have legal responsibility for meeting the requirements in the Health and Social Care Act 2008 and associated Regulations about how the service is run.
We received 47 completed CQC comment cards which were all very positive about the service provided. We spoke to one patient directly at the inspection who was also very positive about the service they had received.
Our key findings were:
- There was a system in place for the reporting and investigation of incidents and significant events. However, there was limited documentation in relation to the investigation of incidents and lessons learnt were not shared widely with staff within the practice.
- Systems and processes were in place to keep people safe. However, these systems were not effectively operated to ensure care and treatment to patients was provided in a safe way in relation to Health & Safety and Legionella risk assessment, safeguarding, infection control, equipment safety, medicines management and medical emergency provisions, business continuity planning and compliance with Ionising Radiation (Medical Exposure) Regulations 2000 (amended 2006 and 2011) [IR(ME)R] and Ionising Radiations Regulations [IRR] 1999 requirements, confirmation of professional indemnity insurance and patient safety alerts.
- Staff were aware of current evidence based guidance. Non-clinical staff had been trained to provide them with the skills and knowledge to deliver effective care and treatment. However, at the time of the inspection the practice was unable to provide confirmation of training in all areas undertaken by staff.
- Quality improvement and monitoring was exercised through ongoing quality assurance of visa medical reports by the two directors.
- There were formal processes for employed staff to receive an appraisal. However, these processes had only recently been reinstated after a period in abeyance.
- Staff we spoke with were aware of their responsibility to respect people’s diversity and human rights.
- Patients were able to access services from the practice within an appropriate timescale for their needs.
- There was a complaints procedure in place, however there was no evidence of the communication within the practice of lessons learned from complaints.
- Clinical leadership and oversight was not formally stated in a strategy or development programme but was exercised mainly by the directors in quality assuring visa medical reports and regular written correspondence and updates with doctors.
- There were potential risks to the security of patient identifiable information.
- The practice did not maintain accurate up to date information about all staff it employed, in particular in relation to training completed by radiographers and doctors employed with practising privileges.
We identified regulations that were not being met and the provider must:
- Ensure care and treatment is provided in a safe way to patients.
- Introduce effective systems and processes to ensure good governance in accordance with the fundamental standards of care.
You can see full details of the regulations not being met at the end of this report.
In addition the provider should:
- Review the system for knowing about notifiable safety incidents to raise staff awareness of the notification requirements under the duty of candour.
- Review recruitment processes to ensure all pre-employment checks are completed in accordance with practice policy, particularly with regard to references.
- Review the induction processes to consider consistency in induction between directly employed staff and those employed with practising privileges.
- Review the facilities for those patients who are hard of hearing.
- Review the need for an emergency pull cord in the patients’ toilet.
- Arrange for lessons learnt from complaints to be shared with all staff.