HIQA in Residential Care: Learnings for International Protection Accommodation Services

Introduction

International Protection Accommodation Services (IPAS) provide accommodation to people seeking asylum or international protection in Ireland. As these centres cater to vulnerable populations, it is widely accepted that regulation and monitoring of the sector is needed to ensure that services prioritise residents’ rights, health, safety, and dignity.

Consequently, it is noted in HIQA’s recently published HIQA Annual Report 2022, that regulation of the sector is swiftly approaching. HIQA commented that they have “undertook work and preparations to establish a regulatory function for the monitoring and inspection of International Protection Accommodation Services (IPAS)”.

Given that HIQA are keen to progress the regulation and monitoring of International Protection Accommodation Services in Ireland, we prepared this blog as an opportunity to reflect on HIQA’s monitoring of other health and social care settings, in particular the residential care settings for older people. HIQA have been monitoring nursing homes since 2009 and as such there is a vast amount of learnings that can be taken from HIQA’s monitoring of residential care settings for older people which can be used to guide us in our approach to preparing for IPAS regulation.

Learnings from Residential Care Sector

HCI review the inspection findings of residential care centres for older people on a quarterly basis and publish these findings as a report. From our latest review we have identified the below areas of non-compliance which provide learning opportunities for IPAS.

Governance and Management

• Inspectors found that the organisational structure in the residential centre on the day of the inspection did not provide assurance that the Registered Provider had a clearly defined management structure that identified clear lines of authority and accountability.
• A number of areas requiring action identified in a previous inspection had been addressed but not sustained or had not been addressed to date.
• The quality assurance systems that were in place did not ensure the quality and safety of the service was effectively monitored. For example, disparities between the consistently high levels of compliance reported in the residential centre’s own audits did not reflect the Inspectors’ observations during the inspection.

Policies and Procedures

• All written policies and procedures were not available to staff working in the residential centre on the day of the inspection.
• A number of policies required by Schedule 5 of the regulations were in not place in line with regulatory requirements.
• Several policies reviewed were out of date.
• A review of the policies used to guide practice in the residential centre found that while appropriate policies were in place, they were not implemented.

Incident Management

• The residential centre had not notified the Chief Inspector of a safeguarding incident as required by the regulations.
• The Inspector identified six incidents that had not been notified to HIQA and met the criteria for notification to the Office of the Chief Inspector.
• Three incidents, as set out in Schedule 4 of the regulations, pertaining to an allegation of abuse were not notified to the Chief Inspector, within the required time frames.

Complaints Management

• No complaints had been documented in the complaints log since May 2021 despite staff awareness of some complaints received.
• The residential centre’s complaints management policy and procedure did not include all the requirements of Regulation 34. The following gaps were identified by Inspectors:
  • There was no person appointed to ensure all complaints were appropriately managed.
  • The complaints management policy did not include an appeals process.
  • Complaints reviewed by Inspectors did not include an investigation.

Risk Management

• The risk management system in place failed to clearly identify risks and the action taken to mitigate risk. This meant that some risks were not identified and managed, to ensure residents safety.
  • Risks identified on the last three inspections were not identified and managed within the residential centre’s risk register.
  • Risk was not assessed, or controls put in place, regarding issues such as an unsecured room as part of the building site that opened on to the main corridor; appropriate precautions were not in place in this room regarding the risk of aspergillus, risk of fire and the requirement to issue an immediate action plan.

Premises

• Actions by the Registered Provider were necessary to ensure that the layout and design of the premises is appropriate to the number and needs of residents in the residential centre and in accordance with residential centre’s Statement of Purpose.
• The Registered Provider had not ensured that the premises conformed to the matters set out in Schedule 6 of the regulations:
  • Wall surfaces in a number of areas were scuffed and had paint missing and required repair and repainting.
  • Lighting in some rooms was not working.
  • Exposed nails protruded along the corridor walls and door frames, posing a risk of injury to residents.
  • Floor covering in several rooms was worn and uneven in parts, posing both an infection control risk and tripping hazard to residents.

Fire Precautions

• There were inadequate precautions against the risk of fire:
  • There was no documented plan to address the outstanding red risks in the residential centre, identified in fire safety risk assessment one year previously.
  • There was a lack of fire extinguishers in several areas of the residential centre.
  • The emergency plan was not updated to reflect the risk of fire as per the residential centre’s own fire safety policy.
• There were inadequate fire containment measures in the residential centre, which posed significant risks to safety.
• The arrangements for providing adequate means of escape including emergency lighting were not effective.
• The arrangements for evacuating residents required improvement.

Training & Staff Development

• Training records reviewed by the Inspector did not provide evidence that all staff had received mandatory training.
• The Registered Provider had introduced an online training programme for staff, which included 12 training components. However, there was minimal oversight of the completion of this training.
• While staff received appropriate training, staff supervision was not sufficient to ensure that the staff training was being implemented in practice.

Infection control

• The Registered Provider had not ensured effective governance arrangements were in place to ensure the sustainable delivery of safe and effective infection prevention and control and antimicrobial stewardship.
• The Registered Provider had not ensured that potential outbreaks of respiratory infection were prevented or identified in a timely and effective manner.
• There were no periodic and deep-cleaning schedules for environmental cleaning to outline clear responsibilities of staff, roster of duties and the frequency of cleaning required. This may result in areas around the residential centre not being cleaned.

How can HCI help?

With the new regulation framework for IPAS comes challenges and opportunities for your organisation. HCI recognise that resources and knowledge of such a regulatory environment may be limited and so we are here to help reduce the burden of compliance. HCI has been working with health and social care organisations almost two decades, supporting them in building Quality and Safety Management Systems that fulfil regulatory requirements and drive improvement in their services.

HCI offer a number of services that will support you in preparing for regulation:

• Gap Analysis against the National Standards for accommodation offered to people in the protection process
• Education and Training
• Risk Management
• Governance System Reviews
• Quality Improvement Planning
• Quality and Safety of Care Audits
• Incident Management
• Complaint Management

Gap Analysis against the National Standards for accommodation offered to people in the protection process

If you are interested in getting a baseline assessment of where you stand in terms of implementing the National Standards for accommodation offered to people in the protection process, then HCI can conduct a Gap Analysis of your service against the standards. We will provide you with a comprehensive report detailing the areas of good practice and areas for improvement, develop Quality Improvement Plans (QIPs) to address areas of concern and support you to implement the QIPs.

If you would like any further information, please contact HCI on 01 629 2559 or info@hci.care.