We carried out an announced comprehensive inspection on 19 July 2018 to ask the service the following key questions; Are services safe, effective, caring, responsive and well-led?
Our findings were:
Are services safe?
We found that this service was not providing safe care in accordance with the relevant regulations.
Are services effective?
We found that this service was not providing effective care in accordance with the relevant regulations.
Are services caring?
We found that this service was providing caring services in accordance with the relevant regulations.
Are services responsive?
We found that this service was providing responsive care in accordance with the relevant regulations.
Are services well-led?
We found that this service was not providing well-led care in accordance with the relevant regulations.
We carried out this inspection under Section 60 of the Health and Social Care Act 2008 as part of our regulatory functions. This inspection was planned to check whether the service was meeting the legal requirements and regulations associated with the Health and Social Care Act 2008.
Health Counts is a medical skin laser and aesthetic clinic. They offer laser hair, thread vein and tattoo removal, dermal fillers, acne treatments and Botulinum Toxin (Botox) treatments for cosmetic purposes and for migraine pain, Bell’s Palsy (temporary facial paralysis) and Hyperhidrosis (excessive sweating).
This service is registered with CQC under the Health and Social Care Act 2008 in respect of the provision of advice or treatment of clients suffering with migraines or Bell’s Palsy with the use of Botulinum Toxin and for the treatment of Hyperhidrosis. The treatment of clients with Botulinum Toxin was undertaken solely by a registered nurse prescriber, which included the prescribing of medicines. At Health Counts the aesthetic cosmetic treatments, including the use of laser treatments, that are also provided, are exempt by law from CQC regulation and were therefore not inspected.
The service is registered with the CQC under the Health and Social Care Act 2008 to provide the following regulated activities:
- Surgical procedures
- Treatment of disease, disorder or injury.
The Managing Director is the Registered Manager. A Registered Manager is a person who is registered with the Care Quality Commission to manage the service. Like registered providers, they are ‘registered persons’. Registered persons have legal responsibility for meeting the requirements in the Health and Social Care Act 2008 and associated Regulations about how the service is run.
As part of our inspection we asked for CQC comment cards to be completed by clients prior to our inspection visit. We received 26 comment cards from clients who provided feedback about all aspects of the service. They were all very positive about the standard of care received. Comments included that the service provided brilliant aftercare and that the staff were professional, kind and caring. One card had mixed comments and included an issue with a payment plan.
Our key findings were:
- There was an effective system in place for reporting and recording significant events and these were monitored to completion. There was a process for sharing the learning within the service, when appropriate.
- Information about the service and how to complain was available and easy to understand. There was an effective system for responding to and learning from complaints.
- The service had systems in place for the receiving of and acting on, safety alerts regarding the monitoring of medicines or devices.
- Systems were in place to ensure that all client information was stored and kept confidential. We saw all paper client records were securely held within a locked cupboard.
- The service carried out fire drills and fire equipment checks were up to date; however, they did not have a current fire risk assessment available to us on the day of inspection or formal fire awareness training. Following the inspection, we were provided with a fire risk assessment.
- Staff acted as chaperones, however the service did not have a policy or procedure for this role and had not offered training to staff undertaking this role. Staff members who acted as chaperones were not checked under the Disclosure and Barring Service (DBS) and a risk assessment had not been completed to determine why DBS checks were not required. (DBS checks identify whether a person has a criminal record or is on an official list of people barred from working in roles where they may have contact with children or adults who may be vulnerable). Following the inspection, the Provider took some action in relation to this finding and applied for all relevant DBS checks.
- The service did not carry out appropriate recruitment checks on newly appointed staff, including, references, eligibility to work within the UK, DBS checks where relevant, and photographic identification. Following the inspection, the Provider took some action in relation to this finding and implemented a recruitment policy, an annual staff declaration form, updated staff files and applied for the relevant DBS checks.
- The service did not have a clear policy or procedure for the safeguarding of children. The service provided safeguarding training for staff in November 2017, however new staff had started after this date and had not completed any safeguarding training. There was no record of safeguarding training for the nurse prescriber. Checks were not carried out on adults accompanying children to confirm identity prior to providing consent to treatment. Following our inspection, the nurse prescriber undertook safeguarding training.
- The service had not conducted the appropriate risk assessments for the necessity of an automatic external defibrillator (AED) and oxygen available for use in medical emergencies and emergency medicines were limited to a measured dose of adrenaline to treat an anaphylactic reaction and Hyalase (helps break down dermal fillers where necessary). Staff had not undertaken basic life support training. We were informed the Provider took some action in relation to this finding following our inspection. We saw evidence that the provider had requested first aid at work training for a number of staff within the service for a future date.
- The service did not document any clinical audits or non-clinical audits to monitor quality as part of an improvement programme, there were no audits in relation to the efficacy of treatments, for example; prescribing audits or infection prevention and control audits.
- The Legionella risk assessment required review to include how and when water temperatures were checked and recorded, and what the level of risk was for the water cooled equipment. We were informed the Provider took some action in relation to this finding following our inspection. The provider amended the risk assessment to include the relevant information and implemented monthly testing.
- The service completed a temperature check list weekly for one fridge out of two in use for the storage of medicines. A separate freezer held stocks of Botulinum Toxin (Botox), and there were no documented checks. The appliances were domestic and not specific for medicines storage, did not have locks on and were in a room accessible by the public and therefore were not secure. We were informed the Provider took some action in relation to this finding following our inspection. Daily temperature checks were implemented for all fridges and the freezer, with actions to take if the temperatures fell outside of range and the appliances were moved into a secure room.
- The service did not have an awareness or adequate training for infection prevention and control (IPC) and had not completed any audits. We were informed the Provider took some action in relation to this finding following our inspection. We saw evidence that the nurse prescriber undertook infection prevention and control training and the provider had requested additional advice from an appropriate source regarding training for staff on IPC.
We identified regulations that were not being met and the provider must:
- Ensure care and treatment is provided in a safe way to clients.
- Establish effective systems and processes to ensure good governance in accordance with the fundamental standards of care.
You can see full details of the regulations not being met at the end of this report.
There were areas where the provider could make improvements and should:
- Improve checks on adults accompanying children to confirm identity prior to providing consent to treatment.
- Embed the new process for medicines kept in cold storage within the service.
- Embed the new recruitment processes and procedures within the service.
- Ensure all members of staff have received fire awareness training.
The impact of our concerns is minor for clients using the service, in terms of the quality and safety of clinical care. The likelihood of this occurring in the future is low once it has been put right. We have told the provider to take action (see full details of this action in the Requirement Notices at the end of this report).