Developing risk based inspection

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Developing risk based inspection

• Alex Baylis
• Healthcare Commission

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Traditional inspection

• Our inheritance from the NCSC included
• methodology designed with aim of forcing
  compliance
• 1200 registered establishments with one self
  assessment form for all (over 180 pages)
• planning often done in the car park, 10 minutes
  before the inspection started
• backlog of over 1000 unpublished inspection
  reports
• overwhelming workload little time for follow-up

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Structure process outcome

• Weve made significant changes to structure and
  process
• tailored self assessments for each type of
  establishment, focused on implementation rather
  than existence of policies
• a short report, designed to be published within
  four weeks of inspection and a clear basis for
  action planning
• specific rules, and structured decision support
  tools to use them consistently
• in 2005, rules to focus inspection only on areas
  at risk of non compliance
• from 2006, further rules to decide whether
  inspection is needed at all
• next stage of development is to further codify
  what we mean by risk and assurance

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Behaviour and culture

• Just as important as assessment tools in
  promoting improvement

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Behaviour and culture cont

• We are increasingly using more levers than just
  inspection
• the risk assessment process
• spot checks, themes and national studies
• other regulators and assessors
• fee incentives
• reputational incentives
• commissioners (PCTs and PMI)

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Approach to risk assessment

• Reducing overlap, increasing collaboration
• local risk summits
• common consensus on areas of concern
• further developing this approach
• testing out with providers through specific pilot
  sites
• Common risk assessment framework
• key means of aligning approach across NHS and
  independent healthcare
• basis for further development

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Case study 1 120 bed acute hospital

• 2004
• 5 inspectors on site for 2-3 days each
• 80 standards assessed against 526 criteria
• 12 requirements plus 25 recommendations but
  many are unfocused or burdensome (e.g. policies
  need to be cross referenced to other important
  documents so that consistent information is
  available... review floor cleaning equipment
  sponges should be replaced with disposable mop
  heads)

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Case study 1 120 bed acute hospital

• 2005
• 3 inspectors, ½ to 1½ days on site
• inspection focused on specific areas
  paediatrics, surgical laser, dialysis, infection
  control, medicines management, and staff
  recruitment
• 8 requirements, which are appropriate and clear
  (e.g. Risk assessments in the dialysis unit were
  incomplete and undated. The Registered Person
  must ensure that every department has an up to
  date COSHH file which includes...)

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Case study 1 120 bed acute hospital

• 2006
• previous inspections show mostly administrative
  lapses, which were acted on promptly
• all issues from last years inspection addressed
• satisfactory evidence from self assessment and
  data
• no inspection this year

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Case study 2 Hyperbaric chambers

• Type 3 chambers
• Currently in pilot stage, the next update of
  methods includes
• explicit weighting of key risk factors
• higher level focus on regulations rather than
  standards
• designed with the sector so that establishments
  should be able to demonstrate assurance by
  cross-referencing a combination of peer review,
  insurers data and oxygen suppliers data no
  bespoke information requirements

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Questions?