In July 2015, the Department of Health (DoH) updated its Code of Practice on the prevention and control of infections and related guidance under the Health and Social Care Act 2008. The Code applies to registered providers of all healthcare and adult social care in England and it reflects the changes required to meet The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.
CQC tend to inspect infection control under Regulations 12 and 15 of the 2014 Regulations. Regulation 12 states that care and treatment must be provided in a safe way for service users and providers are responsible for ‘assessing the risk of, and preventing, detecting and controlling the spread of, infections, including those that are health care associated’. Regulation 15 states that all premises and equipment used by the service provider must be clean and providers must ‘maintain standards of hygiene appropriate for the purposes for which they are being used’.
Although compliance with the Code is not a legal requirement and providers can demonstrate that they meet the Regulations in a different way from that described in the guidance, adherence with the Code is likely to be an easier way to demonstrate compliance. If providers decide to use alternative approaches they should be prepared to justify to CQC how the chosen approach is equally effective or better in ensuring that they comply with the Regulations.
The Code sets out the 10 criteria against which a registered provider will be judged on how it complies with the registration requirements related to infection prevention. Not all criteria will apply to every regulated activity. To meet the 10 criteria, the provider will need to demonstrate the following:
- There are systems to manage and monitor the prevention and control of infection. These systems use risk assessments and consider the susceptibility of service users and any risks that their environment and other users may pose to them.
- They provide and maintain a clean and appropriate environment in managed premises that facilitates the prevention and control of infections.
- They ensure appropriate antimicrobial use to optimise patient outcomes and to reduce the risk of adverse events and antimicrobial resistance.
- They provide suitable accurate information on infections to service users, their visitors and any person concerned with providing further support or nursing/ medical care in a timely fashion.
- They ensure prompt identification of people who have or are at risk of developing an infection so that they receive timely and appropriate treatment to reduce the risk of transmitting infection to other people.
- They have systems to ensure that all care workers (including contractors and volunteers) are aware of and discharge their responsibilities in the process of preventing and controlling infection.
- They provide or secure adequate isolation facilities.
- They have secure adequate access to laboratory support as appropriate.
- They have and adhere to policies, designed for the individual’s care and provider organisations that will help to prevent and control infections.
- They have a system in place to manage the occupational health needs and obligations of staff in relation to infection.
The Code also sets out guidance about how to interpret the criteria. For example, in relation to the first criterion, the guidance states that providers should have appropriate management and monitoring arrangements in place. These arrangements should ensure that among other things, there is a clear governance structure and accountability which identifies a single lead for infection prevention and this person should be directly accountable to the head of the registered provider.
The Code also sets out how providers can develop risk assessments in relation to each of the criteria. So for example, in relation to the first criterion a provider should ensure that the risk assessment has:
· made a suitable and sufficient assessment of the risks to the person receiving care with respect to prevention of infection;
· identified the steps that need to be taken to reduce or control those risks;
· recorded its findings in relation to the first two points;
· implemented the steps identified; and
· methods and interventions in place to monitor the risks of infection to determine whether further steps are needed to reduce or control infection
At Ridouts, we have noticed that the cleanliness of premises and infection control is definitely on CQC’s agenda during inspections. Examples include inspectors examining the under surfaces of chairs for ‘deposits and debris’ and checking laundry areas for dust! Whilst these are extreme examples, it is clear that some inspectors are taking a tough stance in relation to infection control and we would advise providers to review the new Code of Practice and update their policies and procedures in line with this guidance.
A copy of the Code of Practice can be found on the Department of Health’s website at the following link: