Practical tips to prepare for Statutory Licensing

Introduction

At present there are no regulations governing the homecare sector, but we know from the Sláinetecare Implementation Strategy that statutory licensing is coming. The Sláintecare Implementation Strategy notes that a new overarching governance framework will be introduced, and clinical governance will be underpinned by legislation through the introduction of a system of licensing for hospitals, community (including homecare) and other clinical services.

Why do we need licensing?

The introduction of licensing for healthcare services will improve the quality, safety and reliability of healthcare in Ireland. Licensing is important because it helps to:

• Meet public, provider and professional expectations
• Promote responsibility and accountability
• Promote healthcare that is up to date, effective and consistent
• Measure improvements and addressing gaps
• Provide a sound basis for planning, funding
• Improve stakeholder confidence and trust

About the HIQA National Standards for Safer Better Healthcare

The HIQA National Standards for Safer Better Healthcare will support the proposed licensing of hospitals, ambulance services, community care, primary care and general practice.

The HIQA National Standards for Safer Better Healthcare, released in 2012, describe a vision for high quality, safe healthcare. Since their release, the standards underpin many of HIQA’s subsequent standards and guidance documents across all healthcare sectors, so it is safe to assume that when licensing is introduced for Homecare, HIQA will incorporate the eight themes identified in the National Standards for Safer Better Healthcare.

When we get towards licensing, HIQA will be asking providers for self-assessment in relation to compliance with the standards before the licensing is rolled out. When it is about to go live, we expect there will be a period for providers to embed the standards into their organisations. However, this could be a short time frame given that the National Standards for Safer Better Healthcare were introduced in 2012.

Implementation of the HIQA National Standards for Safer Better Healthcare

Implementing a Quality and Safety Framework that incorporates the HIQA National Standards for Safer Better Healthcare, will be a large project for your organisation. It will require a dedicated project leader and a project team.

During the planning stages consider conducting a Gap Analysis against the National Standards for Safer Better Healthcare. The Gap Analysis will allow your organisation to identify where the gaps in the service are. A triangular approach should be used to gather findings from a document review, process observation and staff interviews. From this, you will be able to identify the key areas for concern and put a quality improvement plan in place to address them. During the inaugural team meeting, determine objectives and agree the project plan. Following this, the project team should review the governance structures, conduct risk assessments and agree quality improvement plans.

The project team must critically examine the standards and interpret them based on your service. They will need to link them with other HIQA Standards, HSE Guidance and other tools that may already be in place within your organisation. The project team will need to develop an action list, assign responsibility of tasks and define time frames.

What to expect during a HIQA inspection?

Most of the inspection visit will be spent:

• Meeting with service users and relatives
• Observing the day to day routines and activities
• Talking to staff about their understanding of the care they deliver
• Checking the premises and equipment to ensure they are safe and promoting the wellbeing of service user
• Reviewing key records and relevant documentation

Before the inspection

• Be familiar with relevant documents, SI’s and Standards.
• Make sure previous non compliances have been addressed.
• Keep any information about how service user views the service and any improvements made as a result.
• Have available complaints and concerns.
• Notify the Chief Inspector of any significant changes to the service.

Focus areas for preparation

Staff Participation: Communicate with staff pre-inspection. Provide formal training to them on the inspection process so that they are reassured and have an idea of what they are to say and do. Provide good examples, focusing on person-centred care. Make sure that they are aware of the inspection date.

Service user Involvement: Inspectors will want to speak with the service users, so it is important to inform them in advance of an inspection. Consider having service user representatives and also identify any service user who may not wish to be involved.

Documentation: Make sure to have the required information available for the inspector. Ensure that it is in a clear, accessible format, well organised and that service user’s confidentiality is maintained. Avoid having old, out of date documentation or poorly photographed / reproduced information.

Management Involvement: The Person In Charge (PIC) will be required to meet the inspector on arrival and outline how the service is being delivered in line with its statement of purpose and function. After the inspection there will be a PIC feedback meeting where the inspector will give feedback on their preliminary findings. Have key information ready such as continuous improvement examples, environment maintenance, complaints management, protection from abuse, staffing and recruitment.

Environment & Equipment: Ensure the fire exits are clear, have service/maintenance records for all equipment, have evidence of health and safety assessments. For hygiene and infection control have posters available, information for staff and evidence of hand washing.

Logistics: For the day of the inspection, identify a key person for the inspector to liaise with and provide them with a private room that has a sign on the door. Have the introduction presentation set up and any key documentation available. Make sure there is no confidential information in the room. Ensure there is access to paper, pens, water and refreshments throughout the day.

Remember to ground yourself, clarify your thinking, keep a positive outlook and be open to feedback.

Key Performance Indicators (KPIs) and Data Monitoring

KPIs are used to identify where performance is good and meeting desired standards, and where performance requires improvement (HIQA, 2013). One of the biggest trends today is using data to monitor services. When using data make sure it is relevant, timely and as specific as possible.

Organisations should identify KPIs that are applicable to their service. You need to have the rationale behind why you are measuring each KPI and how exactly you are going to measure it. KPIs should be reviewed regularly to make sure that they are still relevant for your service.

Rather than displaying numbers in a table format, organisations should be aiming to display information in graphs trended over a time period. This demonstrates that you are looking at trends and information to identify issues or changes occurring in your organisation.

Appropriate data monitoring will drive informed decision making and encourage good quality healthcare.

In summary…

Legislation of homecare is coming. In order to be prepared, organisations should now be looking to the HIQA National Standards for Safer Better Healthcare as a guide to prepare their service. Ask yourself:

• Do we know where the gaps in the service are? (Gap Analysis)
• Are our processes clear? (Policies & Procedures)
• Are we checking that it is being done? (Audit)
• Are we minimising risk? (Risk Management)
• Have we a clear plan? (Strategic Plan)
• Are we monitoring our service delivery? (Data Monitoring)