Providers of care are expected to ensure that service users are “protected from the risks of inadequate nutrition and dehydration…” (Regulation 14 Health and Social Care Act 2008 (Regulated Activities) Regulations 2010). This can be tricky when service users have a variety of special dietary and nutritional needs that are being monitored by a number of healthcare professionals. Providers need to be sure that all of these needs are being met and the steps taken are recorded accurately in the care documentation related to each individual.
A number of tools are available to monitor and assist service users who have difficulty with eating and drinking. Where such difficulties arise, the relevant third party should be contacted immediately (e.g. GP, dietician, speech and language therapist) and a plan of action should be implemented. This plan could involve the use of the MUST tool or the introduction of a new diet. All too often, providers monitor weight but take no action when weight falls to dangerous levels. It is sensible for weight charts to clearly indicate the weight below which carers need to take action.
During an inspection of this outcome, CQC will generally monitor service users as they eat and may inspect the records of those service users. It is vital that all documentation related to nutrition and indeed all other aspects of a service user’s care, be completed clearly and accurately. We at Ridouts have seen many occasions where CQC have found documents relating to nutrition that show gaps in recording or no staff signature on the record. Whilst it is likely that this has happened as the result of a minor administrative oversight, CQC have concluded that this gap means that the person was either not fed or that they were not closely monitored. They may make this assumption even if there have been no negative repercussions for that service user. If CQC make such an assertion in a draft review of compliance, providers should not be afraid to challenge that judgment during the factual accuracy process. Whilst poor recordkeeping is obviously unacceptable, it does not necessarily mean that a service user’s needs are not being met and CQC should not be allowed to jump to such a conclusion and mislead those who read their reports.
Providers should avoid situations like this by ensuring that staff are fully trained on how to keep such records. Quality assurance systems should also ensure that providers regularly check that documentation is complete so that any shortfalls are spotted before inspectors visit.
CQC inspectors will also be monitoring whether or not service users’ dignity and rights are being respected during mealtimes. Inspectors have been known to make snap judgements based on what they see when a service user is eating. For example, if they note that a service user eats their meals in their room, they may assert in the draft review of compliance that they are not being included in the communal experience of mealtimes and therefore their needs are being met. However, had the inspector reviewed the care plan records of the service user, they would have seen that they prefer to eat meals in their room and therefore, their wishes are being respected. It is vital that you ensure that inspectors triangulate the evidence that they have gathered through observations with the care plans of the individual concerned. If you receive a draft review of compliance which is not a true record of the situation at your home and the inspector has failed to take into account all available information, be empowered to challenge the inspector’s assertions during the factual accuracy process.
As with all areas of compliance, evidence is key. Don’t wait until inspectors visit – check now that you have the documents necessary to evidence the great care you provide.