Compliance – Are You Prepared?

Simon and Dr Jon Sproson – experienced dentist, Breathe coach, and Clinical Assessor – recently ran a workshop day at The Royal College of Physicians in London. Jon is a qualified assessor and one of the few knowledgeable experts in the country on what is required for upcoming revalidation, HTM01-05, registration and compliance. In this article, Jon gives you a taste of what you need to do and why you shouldn’t put off being prepared.

Those of you who attended the recent Breathe workshop “Don’t Let Them Close you Down: Stay Ahead of the Game!“, will no doubt be well on the way to completing and implementing your plans for compliance with the requirements of HTM01-05 and with registration with the Care Quality Commission.

Here is a reminder for you! For HTM01-05, the essential requirements, spelled out in the document, for cross infection control should be in place by December 2010. No time scale for Best Practice has yet been set in England (unlike in Scotland) and, for many private practices, the question is, ‘should I head for Best Practice in decontamination and cross infection control from the outset?’. Particularly if you are planning new premises or significant alterations in the near future or about to buy a practice, this is highly relevant. Undoubtedly, this will mean for many owners, considerable expenditure (a washer disinfector costs around £5,000).

As I write, the General Election has been called and with it, the consequences of a potential change of Government. One thing is certain, there is unlikely to be additional money available to practice owners to implement the changes required. There is talk doing the rounds that a Tory Government would revisit the question of the validity of HTM01-05 and water down the provisions (which are contentiously lacking an evidence base because of the cost to the supply of Dentistry to implement them). I have no idea whether this is wishful thinking on behalf of the profession or not. I rather think any incoming Government will have its hands full with more pressing issues like the economy rather than worry over what we as dentists will have to spend to comply fully with a public safety issue!

So what to do ? Some will undoubtedly choose to defer any expenditure on expensive pieces of kit to wash instruments until after the Election, in case requirements change yet again – fair enough. But this could also be the excuse for a total lack of activity in preparing for HTM. I think this would be a mistake as the document is unlikely to go away in its entirety and there is much to do. The need to demonstrate the following will all remain:

  • Your whole safety and decontamination procedures and protocols are robust
  • And, they are being carried out
  • And, they are validated
  • And, your staff are fully trained in implementing them

The CQC (Care Quality Commission) are particularly hot at looking at the evidence for staff training, so your training records need to demonstrate that they are all fully up to speed. Oh, and if you do get a CQC inspection next year, don’t be surprised if they interview your staff to check your training records are real! The Healthcare Commission did with my staff. So my advise is to get your “Responsible Person for Decontamination” appointed and start working through the Essential Standards criteria and protocols now. Buying that expensive new kit ahead of an Election, well, that’s your choice. But for those in ‘Quality Practice’ we at least know now what is considered Best Practice by a panel of experts, even if not everyone agrees.

To be continued…

Registration for the Care Quality Commission begins October 2010 and you must be registered by 1st April 2011, which is a legal requirement. Otherwise your premises are not licensed to carry out Dentistry, which is a bit of a bother…

We are now able to offer you Clinical Assessment Days , where we will tailor a day for you in your practice to assess your practice from a clinical perspective (this includes compliance for all the up-coming legislation as well as assessing clinical standards, record keeping etc).

We are running another Compliance Workshop day in London:

“Don’t Let Them Close You Down – Stay Ahead of The Game!”
on Friday 1st October 2010.

If you would like to book a Clinical Assessment Day or attend the Compliance Workshop, please contact Ernie on 0845 299 7209

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