Harley Street Healthcare Clinic

This service is rated as Inadequate overall. (Previous inspection November 2020 - Inadequate)

The key questions are rated as:

Are services safe? – Inadequate

Are services effective? – Inadequate

Are services caring? – Good

Are services responsive? – Requires improvement

Are services well-led? – Inadequate

We carried out an announced comprehensive inspection at Harley Street Healthcare Clinic on 5 July 2021 to follow up concerns identified at our previous inspection in November 2020. At our November 2020 inspection the provider was rated as inadequate overall, placed into special measures and issued warning notices in respect of breaches of regulation 12 (safe care and treatment) and 18 (staffing) and requirement notices for regulation 16 (receiving and acting on complaints) and 17(good governance). The concerns at our last inspection were that:

• The systems to manage infection prevention and control were not effective.
• Not all staff had appropriate recruitment checks carried out at the time they were appointed in line with the provider’s recruitment policy.
• Staff had not received information governance training or the appropriate level of safeguarding children training for their roles.
• The service did not manage medicines appropriately.
• The service did not have an effective mechanism in place to review, disseminate and implement safety alerts.
• Staff did not always have the information they needed to deliver safe care and treatment to patients.
• The service did not always learn and make improvements when things went wrong.
• The service could not demonstrate how improvements were made using completed audits.
• Not all staff had the skills, knowledge and experience to carry out their roles.
• Staff worked together with other organisations occasionally, to deliver effective care and treatment, but there were no systems to follow up on patient referrals.
• The service obtained consent to care and treatment, but this was not in line with legislation and guidance.
• Complaints and concerns were not managed appropriately, and the service did not respond to them properly to improve the quality of care.

Harley Street Healthcare Clinic is a private general medical practice which offers a range of private services to patients such as routine medical checks, health screening, private prescriptions, adult immunisations, travel vaccinations and blood tests.

The lead GP is the registered manager. A registered manager is a person who is registered with the Care Quality Commission 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.

Our key findings at this inspection were:

• Although the provider had made improvements to the premises to address some of the infection control concerns we identified; the arrangements in place to respond to infection control concerns were still not effective.
• Staff had now received information governance training and the appropriate level of safeguarding children training for their roles. However not all staff were aware of the signs and how to respond appropriately to safeguarding concerns and staff had not received training regarding sepsis. The service provided evidence that sepsis training had been completed after our inspection.
• Batch numbers for medicines dispensed were not recorded and we saw that medicines were issued without a clear clinical rationale being documented.
• The service’s paper-based record system meant that the service could not take the appropriate action in response to patient safety alerts.
• Clinical record keeping was not sufficient to keep patient’s safe and ensure that they had the appropriate care, treatment and follow up. Absence of appropriate documentation meant that was unclear if informed consent was being obtained.
• We saw examples of complaints and significant events that were used to make changes to the service provided. However, patients did not receive a written response to formal complaints with details of organisations patients could escalate their complaints to if they were unhappy with the service’s response.
• Staff, whose files we reviewed, had appropriate recruitment checks carried out.
• The service had a limited programme of quality improvement.
• Feedback from patients who completed the providers internal feedback form was positive about the service and the way staff treated them.

The areas where the provider must make improvements as they are in breach of regulations are:

• Ensure care and treatment is provided in a safe way to patients.
• Establish and operate effective systems for identifying, receiving, recording, handling and responding to complaints.
• Establish effective systems and processes to ensure good governance in accordance with the fundamental standards of care.

(Please see the specific details on action required at the end of this report).

The areas where the provider should make improvements are:

• Improve and monitor the process for seeking consent to care and treatment in line with legislation and guidance.
• Improve the facilities in place for people with visual impairments.
• Inform all staff of the requirements associated with safeguarding.
• Check policies and remove reference to any staff member no longer working at the service.
• Undertake quality improvement activity that results in an improvement in the quality and safety of care provided to patients.

Monitoring care and treatment

This service was placed in special measures at our previous inspection in November 2020 and will remain in special measures for a further six months. As with all services that are in special measures following a CQC inspection, this service will be inspected again within six months. If insufficient improvements have been made such that there remains a rating of inadequate for any key question or overall, we will take further action in line with our enforcement procedures to begin the process of preventing the provider from operating the service. This will lead to cancelling their registration or to varying the terms of their registration within six months if they do not improve.

The service will be kept under review and if needed could be escalated to urgent enforcement action. Where necessary, another inspection will be conducted within a further six months, and if there is not enough improvement, we will move to close the service by adopting our proposal to remove this location or cancel the provider’s registration.

Special measures will give people who use the service the reassurance that the care they get should improve.

Dr Rosie Benneyworth BM BS BMedSci MRCGP
Chief Inspector of Primary Medical Services and Integrated Care