Installing Standards into Your Clinic

By Taruna Chauhan / 22 Sep 2021

Business consultant Taruna Chauhan outlines the benefits of implementing CQC standards within your clinic setting

In 2019, 102 aesthetic clinics were registered with the Care Quality Commission (CQC) and this has since risen to 276.1 The increase in registrations is a good sign and I have personally found more and more clinics are thinking about applying.

Aesthetic clinics in England undertaking a regulated activity such as thread lifts and hyperhidrosis treatments, if conducted under the regulated activity of disease, disorder, or injury, should be registered with the CQC.2 However, in clinics where registration isn’t a requirement, benchmarking against the CQC standards means your clinic can be aiming for the highest clinical standards and be ready when it does need to be registered, whilst equally being a great marketing tool if implemented correctly.

This article outlines how CQC standards within England can be used in your clinic setting even if the clinic does not need to be registered with the organisation. Other organisations such as the Healthcare Improvement Scotland, Care Inspectorate Wales and The Regulation and Quality Improvement Authority in Ireland have their own care standards, but as I have worked with clinics mainly in England, I will focus on the CQC for this article.

SCREW

The CQC assessment framework looks at the key lines of enquiry and how these are being met. These enquiries look at five areas and I like to use the pneumonic SCREW to remember these: Safe, Caring, Responsive, Effective, Well-led.

When you complete a task or process, remembering SCREW will help gather relevant evidence and ensure you are aware of which criteria each process aligns with.

  1. Safe: This looks at how you can keep your patients safe by recruiting staff with the correct knowledge and skills, but also ensuring they are given a thorough induction and have regular training and development. Do you have a good safeguarding process in place? How do you store and organise medicines? How do you ensure lessons are learnt when things go wrong?
  2. Caring: This is more intangible. CQC want you to show how you treat patients with compassion and dignity, as well as how you involve them in decisions regarding treatments. How do your staff address patients? Do they speak to them in a kind, friendly manner?
  3. Responsive: Are you a patient-centred organisation? Do you take into consideration the needs of different patients? Do you learn from concerns and complaints? Do you give patients the opportunity to book appointments in a variety of ways?
  4. Effective: Do you monitor outcomes? Do you take consent for treatments? Are your staff equipped with the right skills and knowledge?
  5. Well-led: The CQC will want to know you have a governance framework in place within your clinic. Is there a positive culture? Are there processes in place to ensure staff are developed and skills are up to date? Is there an emphasis on safety and the wellbeing of staff? Do you have a solid grievance procedure?

As a clinic owner you should be covering some of these areas as a matter of course. It is also a good idea to have evidence of this because if/when you choose to exit your business any potential buyers will not only be interested in the data assets you have, but also in all areas as it gives them a rounded image of your clinic. Turnover and profit are important but the story behind them is gold. Building a reputation and having low staff turnover are also key. As you grow your business, run it as if you are going to sell it, which means you want it to be attractive to a buyer in all aspects of the business.

So how can you implement these standards into your own clinic? Let’s go through each key line of enquiry – some of these you are likely doing already so I will focus on showing how it meets the CQC standards.

Safe

I recommend clinics start at the beginning and look at recruitment. Are you using values-based recruitment, thereby attracting staff who have similar values to the organisation? This is important as it helps with employee retention and with the culture of the organisation. Once you have recruited the right person, you also want to ensure that you have a robust induction procedure in place. Clearly informing them of key policies which are usually required at operational level and checking competency of understanding is vital. Arming your staff with the information about the premises, for example fire exits, and your holiday leave is important, as it makes your staff aware of your whereabouts throughout the year. Ensure your staff are informed of what outcomes you expect from them during their induction or if there are any changes in their job role, then a meeting with the clinic owner should be arranged.

How do you maintain good infection control? Do you have a sharps policy, and a good waste management process? Are you auditing for compliance? Hand hygiene should be audited regularly with posters being added to appropriate areas of the clinic. You can contact your local infection prevention control team who can offer an audit and forums to keep up to date with this topic.3 For cleaning, use the Health and Safety Executive (HSE) guidance and the national colour coding system for cleaning areas.4 These are red for sanitary areas, blue for general areas including waiting and consulting rooms, yellow for treatment and minor operations and green for kitchen food areas. There are kits you can buy to ensure your cleaning company is doing this; it is good practice and a benchmark for cleaning standards as this system is widely used in the NHS and assists with infection control. Check if they are a member of the British Institute of Cleaning Science (BICSc) as they should be following guidance and standard protocols if they are.5

Caring

Showing dignity to your patients means being respectful of their culture and needs. Being kind and compassionate involves the language and tone used, and you can show evidence of this through the feedback you receive from your patients. Within the staff room, you could have a gratitude wall to highlight good feedback. This practice enables you to have a team that cares for each other, and this will be reflected in how they speak with patients too. I find it useful to look at the patient journey and how you personally would like to be spoken to, treated and feel whilst at the clinic.

Responsive

Showing that you are responsive to your patient’s needs covers a couple of key areas. CQC want to know how accessible your booking system is. Are patients able to book in a manner which suits their needs? Are they able to book a time which suits them? Do you have evening and weekend slots?

When situations arise, do you have a process in place to deal with it and how responsive are you in this situation? Ideally you want to be able to deal with the issue straight away. Everyone should have a complaints policy as errors will occur, often minor but sometimes major, and a system to respond to these is imperative. Asking for feedback is a good way to see if you need to improve or change anything in your clinic. A patient may see things differently to you, therefore gaining an understanding of their viewpoint is important.

Effective

Do you have processes and procedures in place which are followed consistently? Do you have a governance framework or standard operating procedures in place to check and audit that staff are following processes? This is particularly important when something goes wrong as you can usually pick out a step missed or a move away from the written process.

Processes and procedures do not need to be tomes. They need to be clear, to the point and easy to understand. It is good to consistently check the competency of your staff and to have a training matrix within your clinic, so you are aware that all staff are up to date with relevant learning and CPD. In a busy environment, it is easy to forget mandatory training refresher courses, so schedule in some time to ensure this is completed.

Well-led

A collaborative approach is now seen as a better way of leading. The hierarchal way of working is slowly becoming less popular, with organisations moving towards working collaboratively at all levels. This ensures that everyone takes responsibility for the whole business, rather than one area.

All staff should know what is expected of them in their role, and their outcomes. Performance should be managed well so that anyone within a role can take the lead at any given time. This also supports a team atmosphere where each member of staff gives back to their colleagues. I recommend asking staff to undertake psychometrics tests to see the makeup of your team and help with the communication, allowing you to recognise the key skills of your staff. There are many free ones which I use with my clients, including Via Character and 16Personalities.6,7

How well do you manage information? Are you meeting the General Data Protection Regulation? Are you registered with the Information Commissioner’s Office? Are your staff aware of cyber security and the importance of strong passwords and not sharing them? In an age where we rely on IT, cyber security is essential. The Exercise in a Box is an online tool which helps organisations find out how resilient they are to cyber-attacks and practice their response in a safe environment.8 This is available on the National Cyber Security Centre website.9

By looking at how your organisation can meet the Healthcare Assessment Framework you will be benchmarking against robust criteria. Once you have gone through a cycle of quality assurance and audit, you should be looking at how you can continuously improve. Use the Deming Cycle which states you should Plan, Do, Check, Act.10

Try it yourself!

It is important to remember that being CQC registered should not be seen as a tick box exercise. You really can use it to show continuous improvement within your clinic setting. By doing everything I have mentioned above, looking at the CQC key lines of enquiry and implementing them in your clinic, you will be ensuring that you are heading towards the CQC standards, meaning that if you wanted to start conducting a regulated activity, you will have the correct processes in place. By following the criteria, you will also be able to show to patients that you are benchmarking yourself against standards set by a regulatory body.

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