This service is rated as Inadequate overall.
The key questions are rated as:
Are services safe? – Inadequate
Are services effective? – Inadequate
Are services caring? – Good
Are services responsive? – Requires improvement
Are services well-led? – Inadequate
We carried out an announced comprehensive inspection at Coltishall Cosmetic Clinic on 17 July 2019. This inspection was to rate the service.
Coltishall Cosmetic Clinic is an independent provider of cosmetic services. The clinic is located in the village of Horstead, a few minutes’ drive from the centre of Norwich. They offer treatments for aesthetic and medical purposes.
This clinic is registered with Care Quality Commission (CQC) under the Health and Social Care Act 2008 in respect of some, but not all, of the practices it provides. There are some exemptions from regulation by CQC which relate to particular types of services and these are set out in Schedule 2 of The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. Coltishall Cosmetic Clinic is registered in respect of the provision of treatment of diseases and surgical procedures. Therefore, we were only able to inspect treatments relating to medical purposes, such as Botox for excessive sweating, ultrasound, surgical procedures including mole removal, liposuction and face lifts and weight loss services. The clinic offered other services such as laser treatment for hair removal and tattoo removal and Botox for aesthetical reasons, these services are exempt from regulation.
The practice 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 lead doctor is the registered manager. A registered manager is a person who is registered with the Care Quality Commission to manage the practice. 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 practice is run. The lead doctor is also the nominated individual. (A nominated individual is a person who is registered with the Care Quality Commission to supervise the management of the regulated activities and for ensuring the quality of the practices provided).
As part of our inspection we asked for CQC comment cards to be completed by clients prior to our inspection visit. We received 40 comment cards, all were wholly positive about the service. The cards reflected the kind and caring nature of staff, how informative staff were, the pleasant environment and the positive effects of the treatment received. Other forms of feedback, including patient surveys and social media feedback were consistently positive.
Our key findings were:
We have rated the service as inadequate for providing safe services because:
- The provider told us they did not carry out DBS checks for all staff as most staff had worked at the service for over ten years. (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). Staff who acted as chaperones were not trained for the role and not all have received a DBS checks.
- The systems in place to manage environmental infection prevention and control risks were ineffective.
- The provider did not ensure facilities and equipment were safe and equipment was maintained according to manufacturers’ instructions.
- The provider did not carry out appropriate environmental risk assessments such as legionella, fire and health and safety risk assessments. The provider sent us some risk assessments after the inspection.
- Staff could detail what actions they would take in an emergency, however, they had not had appropriate training in basic life support. Staff had not completed training in safeguarding.
- The clinic did not have the all of the emergency medicines in line with recognised guidance and they had not risk assessed this.
- Individual care records were not written and managed in a way that kept patients safe. For example, some care records were illegible and were not signed by clinicians. We also noted concerns with some of the observations taken for patients which were not shared with the patients’ GP.
- The service did not have a system in place to retain medical records in line with Department of Health and Social Care (DHSC) guidance in the event that they cease trading.
- There was not a clear system for recording and acting on significant events.
- The service told us they were aware of safety alerts, however, there was not a system in place to document receiving, review and action of safety alerts, including medicines safety alerts.
We have rated the service as inadequate for providing effective services because:
- The provider did not always assess needs and deliver care in line with relevant and current national evidence-based guidance and standards.
- We did not always see the clinic gained appropriate information on the patients’ medicines history.
- The service would refer patients back to their registered GP for some issues, however, this was not consistent or in line with their protocol for referring back to the registered GP.
- Staff were not all appropriately qualified. The provider did not have a comprehensive induction programme for all newly appointed staff.
- The provider did not assess the learning needs of staff as there was no evidence of a formal appraisal system.
- Before providing treatment, the doctor at the service asked for an overview of the patient’s health. However, they did not gain reassurance or validate this information.
We rated the provider as good for providing caring services because:
- All patients said they were treated with compassion, dignity, and respect and they were involved in their care and decisions about their treatment.
- The service proactively sought feedback from staff and patients, which it acted on. Regular surveys were undertaken.
We rated the provider as requires improvement for providing responsive services because:
- The facilities and premises had not been risk assessed to ensure they were appropriate for the services delivered.
- Referrals and transfers to other services were not always undertaken in a timely way.
- We saw examples where the clinic was not aware of the Duty of Candour.
We rated the provider as inadequate for providing well-led services because:
- The lead doctor was not knowledgeable about issues and priorities relating to the quality and future of services. They had not put the appropriate systems or processes in place to manage potential risks to the service.
- There were not effective processes in place for providing all staff with the development they needed.
- Structures, processes and systems to support good governance and management were not in place. We found serious concerns relating to the legibility of notes and the observations taken of some consultations.
- The provider had some policies, procedures and activities. However, we found these lacked information to appropriately advise staff.
- The clinic did not have appropriate systems to identify, understand, monitor and address current and future risks including risks to patient safety.
- The service did not fully monitor current and future performance.
The areas where the provider must make improvements are:
- 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 staff are suitably qualified, competent, skilled and experienced persons are deployed to meet the fundamental standards of care and treatment.
- Ensure recruitment procedures are established and operated effectively to ensure only fit and proper persons are employed.
I am placing this service in special measures. Services placed in special measures will be inspected again within six months. If insufficient improvements have been made such that there remains a rating of inadequate for any key question or overall, we will take action in line with our enforcement procedures to begin the process of preventing the provider from operating the service. This will 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 will move to close the service by adopting our proposal to remove this location or cancel the provider’s registration.
Special measures will give people who use the service the reassurance that the care they get should improve.
Dr Rosie Benneyworth BM BS BMedSci MRCGP
Chief Inspector of Primary Medical Services and Integrated Care