14 August 2018
During a routine inspection
This practice is rated as Inadequate overall. (Previous rating 31 August 2017 – Requires Improvement)
The key questions at this inspection are rated as:
Are services safe? – Inadequate
Are services effective? – Inadequate
Are services caring? – Good
Are services responsive? – Inadequate
Are services well-led? - Inadequate
We carried out an announced comprehensive inspection at Dr Tun Lwin on 14 August 2018. This inspection was to follow up breaches of regulation 17 and 19 identified at our previous inspection.
Dr Tun Lwin was initially inspected on 9 December 2016. During that comprehensive inspection we identified concerns in respect of safety arrangements including fire safety systems, recruitment checks including Disclosure and Barring Services (DBS) checks for clinical staff and systems to act on safety alerts. In addition, we found that Patient Group Directions (PGDs) intended to allow nurses to administer medicines in line with legislation had not been authorised by a prescriber as required. We issued requirement notices in respect of breaches of regulation 12 (Safe Care and Treatment), 17 (Good Governance) and 19 (Fit and Proper Person Employed) of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. The provider was rated as requires improvement for key questions: are services safe and are services well led? This meant that the provider was rated as requires improvement overall.
We undertook a focused follow up inspection on 3 August 2017 to see if these breaches had been addressed. This inspection focused on the two key questions rated as requires improvement at the first inspection: Are services safe? Are services well led? We again identified concerns around systems to ensure the safe recruitment of staff and fire safety. We issued the provider with requirement notices in respect of breaches of regulation 17 and 19 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.
At the inspection of 14 August 2018 we found:
- Some individuals undertaking clinical work had not been subject to the necessary recruitment checks.
- Reviews of patient records showed a lack of consistent and clear documentation of interactions with patients and instances where follow up actions were not performed at all or in a timely manner. There was a lack of effective clinical governance arrangements to ensure oversight and completion of clinical tasks.
- The practice did not have adequate systems in place to respond to medical emergencies and not all medical equipment had been calibrated.
- Systems and processes in certain areas did not work effectively including arrangements to safeguard patients from abuse, infection control, the monitoring of consent, significant event management, medicines management and the monitoring of cancer referrals.
- The practice performed well against most clinical targets. However, the practice was not meeting Public Health England targets related to cervical screening and childhood immunisations. We were told that this was related to a lack of nursing time and there were no plans in place to meet these targets.
- Arrangements for recording consent and acting on concerns around a person’s mental capacity were not clear.
- Care planning was inconsistent.
- Complaints were not always responded to in writing in accordance with the practice’s policy.
- There was minimal evidence of quality improvement activity including audit.
- Staff involved and treated patients with compassion and kindness but systems around privacy were lacking and the practice had only identified a small proportion of their patient list as having caring responsibilities.
- Patients found the appointment system easy to use and reported that they were able to access care when they needed it. However, deficiencies in clinical governance hindered the practice’s ability to be responsive to patient needs.
- Complaints were not dealt with in line with the practice policy and information on how to make a complaint was not easily accessible.
- There was a limited evidence of continuous learning and improvement within the practice.
The areas where the provider must make improvements are:
- Ensure that care and treatment of patients is only provided with the consent of the relevant person.
- Ensure care and treatment is provided in a safe way to patients.
- Establish effective systems and processes to ensure good governance in accordance with the fundamental standards of care.
- Ensure sufficient numbers of suitably qualified, competent, skilled and experienced persons are deployed to meet the fundamental standards of care and treatment.
The areas where the provider should make improvements are:
- Consider how best to periodically review patient safety alerts related to contraindicated medicines.
- Improve systems for safeguarding particularly related to chaperoning and training.
- Expand quality improvement activity including clinical audit.
- Improve systems to ensure care plans are drafted where appropriate.
- Ensure all staff are aware of the practice’s business continuity arrangements.
- Improve the practice’s complaints system around accessibility and provision of formal responses.
I am placing this service into special measures. Warning notices have been issued in respect of breaches of regulation 12 and 17 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 with a two-month deadline to achieve compliance. We will reinspect the service after two months to reassess the provider’s compliance with the relevant regulations. If insufficient improvements have been made such that there remains a rating of inadequate for any population group, key question or overall, we may take action in line with our enforcement procedures to begin the process of preventing the provider from operating the service. This may 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 may move to close the service by adopting our proposal to remove this location or cancel the provider’s registration.
Professor Steve Field CBE FRCP FFPH FRCGP
Chief Inspector of General Practice
Please refer to the detailed report and the evidence tables for further information.