Firstly sorry to those who already got this. Server problems meant it only went to a fraction of the list.
Anyway, I couldn’t get over the irony. There I was at a course run by DPL, and we were roll playing how to deal with unforeseen events and unhappy patients. I was the patient, unhappy that I had an abscess that I was accusing the dentist of missing. The dentist playing the, er, dentist had to alleviate my concerns and diffuse the situation. So what did the dentist (who is predominantly NHS) say?
“Well you NEED a root filling, but that is very complex and is only available privately”
I kind of played with him after that, because it was clear he just didn’t GET IT. When the exercise finished I kind of tested the idea that perhaps that statement wasn’t the sort of thing one shouldn’t be saying in this highly litigious society. He wasn’t having any of it, so I dropped it. It’s his decision what he does. And I’m sure he is very good at doing RCT’s. And you know what, this gentleman will be sued, I can almost guarantee it. Why?
- English is not his first language, so there is already a communication issue (he had trouble understanding my accent, so considering he works in Yorkshire……)
- He hasn’t understood the concept that, if it is required to create and maintain Oral Health, it is available on the NHS. He can’t argue about that, because he signed up to the contract.
The guy from DPL was actually walking past when he heard this statement, and I did see his eyebrow raise just a fraction.
This is a very dangerous game for dentists to be playing, and is not one I wish to engage in thank you very much. I have this thing about wanting to sleep at night. I have discussed with DPL and the local dental advisor what treatments, in what situations, are and are not available under NHS contract. I have an understanding which is backed up by my ethical beliefs. I also have a patient base that I largely have rapport with and that I like as individuals. I have systems in place to make sure that the patient journey is acceptable and consistent. Unfortunately I have one small challenge.
You see, it doesn’t matter if you are the best dentist in the world, with the cleanest most high tech premises and the best staff money can buy. That doesn’t mean diddly squat unless you can prove it to a pen pusher. Unless a pen pusher can come in and tick all his (or her) boxes, you are not compliant. And I know, from my relative who used to work in care homes, that these CQC guys like to tick boxes. They are extremely thorough, sometimes even single minded.
If you think you can fob them off with half assed policies and an aggressive, arrogant stance, you may well be in for a nasty surprise.
Now I have BDA Good Practiceat my practice, and I assumed that this would be enough to comply. Their guidance on what aspects of GP related to CQC compliance seemed ok. Unfortunately, it doesn’t even come close to getting you compliant as far as I can now see. You see, the problem is I went on a CQC course the other day (one third done by the very excellent Raj Rattan). I finally got a glimpse of just what the CQC were all about.
It was a bit of an eye opener.
So let’s see where you are. Ask yourself if you have the following 10 items of evidence?
- Do you have an Equality Policy?
- Do you have a Safe Haven Policy?
- Do you have a list of all your equipment, with their CE marks to prove that these items are fit for use in your practice?
- Do you have a Discrimination Policy?
- Do you have a Consent Policy?
- Have you done the HTM 0105 Audit created by the Infection Prevention Society?
- Do you a Confidentiality Policy?
- Do you hold patient Forums, do patient questionnaires, have a suggestion box or even a comment book?
- Do you have a system for ensuring no hand instrument goes more than 21 days without being autoclaved?
- And do you have evidence that all your staff have been trained in all of the above?
Can you guess what I just spent the last 2 days doing? The course I mentioned was run by http://cqcsupport.co.uk/, an organisation set up by a dentist for dentists. They do an excellent manual which I strongly recommend. Don’t get me wrong, this manual will not give you the policies, procedures and evidence you need for the CQC. But, as Raj Rattan stated, it will tell you the evidence you need to collect. And I know there are other versions of this. CODE do one, and so do the BDA. But to be honest, I’m not a great fan of either of these organisations. The membership fees they ask for are extortionate. The CQC support manual can be bought for just under £300. Can I guarantee that it will tell you everything you need to know? Well no of course I can’t. As you know by now, I believe the CQC have left their so called “guidance” deliberately vague. Why they have done that I leave up to you. I know I am compliant, it’s just proving it by getting all the bits of paper together. And that is time consuming. And with the fact that failure to comply is now backed by financial and criminal sanction, I’m not prepared to mess about with this.
As for gathering the evidence, this is where the challenges came in. Bureaucrats like folders, they like paper. They like to see that you have done something. They like to hold it, caress it, take it our for candle lit meals with fine wines and romantic music. And to be fair, for me personally, it’s easier to collate everything if its in paper form. Hence the printer now stationed in my surgery. As I have reached my UDA quota, I can now spend the time I need without cutting into my income or my holidays. Much of what I need I gathered from DPL Extra, a very good resource. Mix that with the old CODE manuals I use and some bits and bobs from that extinct dinosaur called the BDA, and the evidence starts to grow. But you know what?
Stuff was missing. Which really surprised me………..NOT!
I ended up doing a lot of typing over those two days, but I can now provecompliance in the first 2 outcomes. And that has resulted in me personally creating almost 50 sides of A4 in waffle. God knows how much I will have done by the time Outcome 6 is finished. And here is where my business head came in. If I’m going to be sat there typing when I could be immersed in Chalres Bukowski with a bit of Daft Punk in the background, then I’m going to find a way to take advantage of it. Hmm, sounds like old Stevey boy had just come up with a new product.
So for those who are interested, my next product to be released will be called the
Can’t Quite Comply © 2011
product, with all the policies, procedures, signed statements and extra systems I have had to create to keep those lovely chaps at this fine Quango happy. I may even add a special bonus with regards to the Information Governance Toolkit. People will either buy it or they won’t.
But let’s be clear:
- This product alone will NOT make you compliant
- I am not a lawyer or a box ticker, so I cannot guarantee these will even be accepted
- It will however be released shortly
- And it will be priced at less than £100.
I’ll let you know. In the meantime, I strongly suggest checking out http://cqcsupport.co.uk/. Of course, it goes without saying that I will not be held liable for anything that results from your visiting that website. Just thought I would keep my lawyers happy.
Keep well, and remember……
Don’t let the fluffy darlings get you down…….. because then they win. And trust me, you don’t want them to win.