Managing the risks from HCAI The Healthcare Commissions role

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Managing the risks from HCAIThe Healthcare
Commissions role

• Goole Meeting of the ICNA
• 10thJuly 2007
• Amanda Musgrave
• Senior Assessment Manager

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Code of Practice for the Prevention and Control
of Health Care Associated Infections

• The prevention and control of HCAI is a high
  priority for all parts of the NHS.
• It is of equal importance for health care
  providers in the independent and voluntary
  sectors.
• Health Act 2006

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Purpose of the Code

• To help NHS bodies plan and implement how they
  can prevent and control HCAI.
• Sets a criteria by which managers of
  organisations are to ensure that patients are
  cared for in a clean environment, where the risk
  of HCAI is kept as low as possible.

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Who does the Code apply to?

• Acute Trusts including FTs
• Mental health/Ambulance/Primary Care Trust
• Services commissioned by the NHS
• .should satisfy itself that contractors have
  appropriate systems in place to keep patients,
  staff and visitors safe from HCAI, so far as is
  reasonably practicable..

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And politically?
ANDY BURNHAM MP Minister for delivery
quality On infection control, Health Committee,
26 Oct 2006

• I think it goes to the heart of public
  confidence in the NHS , from chief executive
  level downwards there should be leadership and it
  should be a priority for every single
  organisation in the NHS
• .some trusts have made real strides but the
  variation is enormous and there are a large
  number of trusts who are not making enough
  progress.

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The problem our assessment

• Healthcare associated infection
• Just one of many risks in healthcare But of
  great concern
• Prevention and control still problematic (e.g.
  some trusts struggling with MRSA target our
  survey on C.difficile)
• Simple precautions still causing some problems
  (e.g. hand cleaning evidence from latest NHS
  staff survey)
• Hospital cleanliness 2005 snapshot showed
  variable standards
• Stoke Mandeville full investigation

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The regulators toolkit

• Targets
• Standards NHS Independent sector
• Audits, inspections and investigations
• Surveys staff and patients
• Improvement reviews / national studies
• Statutory Code of Practice

Assessments and ratings, registration,
enforcement Promoting compliance
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Purpose of the Statutory Code of Practice on HCAI

• To set out basic requirements for infection
  prevention and control
• To ensure lack of compliance can be clearly
  identified
• Where necessary, to pull poor performers up to a
  minimum standard

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Health Act 2006

• Power for the Sec.of State to introduce the Code
• Duty on NHS bodies to comply
• Duty on the Healthcare Commission to assess
  compliance,
• Power to issue improvement notices

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Scope of the Code

• 3 main areas
• Management, organisation and the environment of
  care
• Clinical care protocols
• Healthcare workers

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Scope of the Code

• Management, organisation and the environment of
  care
• General duty to protect patients, staff and
  others from HCAIs
• Appropriate management systems in place for
  Infection prevention and control
• Assess risks and take action to reduce or
  control such risks
• Provide and maintain a clean and appropriate
  environment for health care
• To provide information on HCAI to patients and
  the public
• Provide information when a patient moves from
  the care of one health care body to another
• To ensure co-operation
• To provide adequate isolation facilities
• Ensure adequate laboratory support

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Scope of the Code

• Clinical care protocols
• minimum set of written policies programme of
  audit, revision and update
• Healthcare workers
• access to occupational health services,
  induction, training

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4. Duty to provide and maintain a clean and
appropriate environment

• An NHS body must, with a view to minimising the
  risk of HCAI, ensure that
• a. there are policies for the environment which
  make provision for liaison between the members of
  any infection control team (the ICT) and the
  persons with overall responsibility for
  facilities management.

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4. Duty to provide and maintain a clean and
appropriate environment

• An NHS body must, with a view to minimising the
  risk of HCAI, ensure that
• b. it designates lead Managers for cleaning and
  decontamination of equipment used for treatment
  (a single individual may be designated for both
  areas).

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4. Duty to provide and maintain a clean and
appropriate environment

• An NHS body must, with a view to minimising the
  risk of HCAI, ensure that
• c. all parts of the premises in which it provides
  health care are suitable for the purpose, are
  kept clean and are maintained in good physical
  repair and condition.

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4. Duty to provide and maintain a clean and
appropriate environment

• An NHS body must, with a view to minimising the
  risk of HCAI, ensure that
• d. the cleaning arrangements detail the standards
  of cleanliness required in each part of its
  premises and that a schedule of cleaning
  frequencies is publicly available.

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4. Duty to provide and maintain a clean and
appropriate environment

• An NHS body must, with a view to minimising the
  risk of HCAI, ensure that
• e. there is adequate provision of suitable hand
  wash facilities and antibacterial hand rubs.

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4. Duty to provide and maintain a clean and
appropriate environment

• An NHS body must, with a view to minimising the
  risk of HCAI, ensure that
• f. there are effective arrangements for the
  appropriate decontamination of instruments and
  other equipment.

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4. Duty to provide and maintain a clean and
appropriate environmentAn NHS body must, with a
view to minimising the risk of HCAI, ensure
thatg. the supply and provision of linen and
laundry supplies reflects Health Service Guidance
HSG (95)18, Hospital Laundry Arrangements for
Used and Infected Linen, as revised from time to
time.
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4. Duty to provide and maintain a clean and
appropriate environmentAn NHS body must, with a
view to minimising the risk of HCAI, ensure that

• h. clothing worn by staff when carrying out their
  duties (including uniforms) is clean and fit for
  purpose.

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The stick

• Improvement notices
• Require compliance failures to be fixed
• Can be issued by inspectors
• If unresolved, refer to Secretary of State or
  Monitor (special measures)
• code of practice .admissible in evidence in any
  criminal or civil proceedings
• Implications for duty of care complaints
  pressures for reactive inspection?
• E.g. Police/CPS, Health Safety Executive (HSE)
  action

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How will this new legislation work best? (1)
Designing.

• Ensure suitable fit with the Healthcare
  Commissions systems for assessment
• (NHS) link with core standards, annual
  declaration 06/07 and 07/08, screening and spot
  checks
• (IHC) extension to the national minimum
  standards regime to reflect provisions of the
  code?

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Legally defined functions/duties Health Social
Care (..) Act 2003

• Annual health check S50 (annual review)
• Each year must conduct a review for each
  English NHS body award rating
• Reviews S51
• Has function to review (various types),
• Primary focus for service improvement
• Investigations S52
• Function to investigate
• Primary focus on cause

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C4a
C4. Health care organisations keep patients,
staff and visitors safe by having systems to
ensure that the risk of healthcare acquired
infection to patients is reduced, with particular
emphasis on high standards of hygiene and
cleanliness, achieving year-on-year reductions in
MRSA.
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The Code core standards (1) - key links
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The Code core standards (2) - other links
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The Code core standards (3) - other links
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What have we done since the Code came into force
on 1 October 2006?

• Initial training for 180 Healthcare Commission
  assessment managers
• Followed up the 41 trusts that declared they had
  not met core standard C4a in 2005/06 to ensure
  improvement action had been taken, taking account
  of the Code
• Gained SoS agreement to amend criteria for core
  standards C4a, C4c and C21
• Required trusts to complete a separate
  declaration on the Code as part of the 2006/07
  annual health check check visits
• Built a surveillance and response capability to
  target inspection visits during 2007/08 to 120
  trusts that may present most risk to check if
  Code is being properly observed

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Key messages

• CEO's, Boards have to lead to make this work it
  involves everyone. And it requires hard work.
• Trusts have many competing priorities, including
  targets, but they must manage these in a way that
  does not neglect the safety of patients
• Safety including HCAI will be a key focus of the
  2007/2008 Annual Health Check
• Consultation on the proposals for the AHC closed
  on 20th April and include
• Monitoring C. difficile rates in addition to MRSA
• Asking trusts to declare compliance with the
  Hygiene Code over a full year
• Ensuring that every inspection on compliance with
  core standards assesses performance on safety

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