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CQC’s social care KLOEs
Do you know what’s changed?

Jonathan Papworth runs through the main changes in CQC’s social care KLOEs.

The Care Quality Commission’s (CQC’s) updated social care Key Lines of Enquiry (KLOEs) and prompts came into force for adult social care in November 2017. They are the result of feedback from a consultation about the original KLOEs, which were published in 2015.

The new KLOEs and prompts reduce duplication and simplify the process for organisations that provide more than one type of service.

CQC says in the Key lines of enquiry, prompts and ratings characteristics for adult social care services document, ‘The changes to KLOEs and prompts are the result of feedback following our Next Phase consultation. We have merged the two previous versions for residential and community care, added new content to strengthen specific areas and reflect current practice, and made some changes to the wording to improve and simplify the language to aid understanding.

‘We have also aligned, as much as possible, the wording of KLOEs and prompts between the two assessment frameworks for healthcare services and adult social care services.’
I believe that these updated KLOEs give some indication of the strategic direction that CQC appears to be taking with its approach to inspection as there are key themes running through them.

CQC’s changing social care KLOEs

The changes to the KLOEs cover all five key questions: Safe, Effective, Caring, Responsive and Well-led, with substantial changes to Safe and Effective. Although, all areas have new questions and substantive changes to wording.

Safe

The Safe category has the greatest number of new KLOEs and prompts, which may be due to fewer than 0.5% of providers being rated Outstanding in this area. The first KLOE is reworded and asks, ‘How do systems, processes and practices safeguard people from abuse?’ with a new prompt, S1.1 which simply asks how safeguarding systems, processes and practices are developed, implemented and communicated to staff.

There are also changes focused on discrimination, with a specific mention of the Equality Act. All workplaces legally must be safe and free from harassment, so employers would normally meet these requirements, although there will be a need to document how these are met, and ensure that both service users and staff are protected.

There are changes in a few areas of section 2, and the S2 KLOE now says ‘How are risks to people assessed and their safety monitored and managed, so they are supported to stay safe and their freedom is respected?’ It is interesting to note that freedom is mentioned, and risks are there to be managed, not to reduce freedom.
There is a new prompt, S2.3 which requires records to be legible, up-to-date and stored securely – as well as being available to the relevant staff. Where records are handwritten on paper this will be a challenge, whilst the need to be stored securely is to bring data storage in line with General Data Protection Regulation (GDPR) which comes into force in May 2018.

KLOE 4 refers to medication, which is an area CQC has been focusing on for a long time. There are changes to ensure storage and administration of medications are properly managed as well as two new prompts.

Prompt S4.7 is new and relates to reviewing medicines at appropriate intervals, which might be to reduce long-term dependency on medication to control behaviour.

Prompt S4.8 is also new and relates to medication and information about medicines when people move between care settings. This points to joining-up care and could reduce the costs and risks involved with medication being lost or thrown away when people transfer between settings.

KLOE 5 focuses on infection control, with new prompt S5.4 asking how external agencies are alerted, where necessary, to concerns that affect health and wellbeing. S5.5 is also new and looks at staff training and procedures for food hygiene.

KLOE 6 is entirely new and focuses on learning from mistakes. It has been added, at least in part, to ensure social care is aligned with health. It seems to be pointing toward transparency; mistakes happen but it is important that they are communicated, lessons learned and improvements made as a result.

There appears to be a major focus in the Safe category on systems and processes, and the link to accessibility, security and legibility makes electronic systems important. Other aspects of the changes appear to be to conform to employment legislation, meet the needs of GDPR, have rock-solid medication processes, and to work effectively with third parties.

Effective

In the Effective category, there are changes to KLOE 1, these include managing differing needs from a holistic perspective in line with legislation, standards and evidence-based guidance to reach effective outcomes, and avoid discrimination, with reference again to the Equality Act.

A new prompt is E1.3 which specifically asks how technology and equipment are used to enhance care.

KLOE 2 relates to staff being trained and have appropriate skills and knowledge to deliver effective care and support. An effective training process would be useful in ensuring this is met and e-learning is fast becoming the most time and cost-effective way to ensure everyone is trained and can be evidenced as such.
KLOE 3 focuses on nutrition: supporting people to maintain a balanced diet, freedom of choice and managing risks, with each prompt having had a substantive change following the consultation response. KLOE 5 also relates to healthy lifestyles.

In between is KLOE 4 with a single prompt E4.1. This looks specifically at working across multiple services and ensuring people’s care is consistent and co-ordinated. It has moved from Responsive to Effective.

KLOE 6’s main question has been amended and there is a change to one of the prompts too, which relates to the environment being suitable to meet needs and promote independence.

KLOE 7 relates to consent to care, and has been moved within Effective with a large number of changes to the prompts, particularly relating to mental capacity, promoting best interests and meeting national legislation/guidance. These changes came from the consultation and could be a reflection of issues around mental capacity and deprivation of liberty.

Caring

The Caring category has several new questions, despite 95% of homes inspected having achieved Good or Outstanding in this area.

KLOE 1 deals with treating people with kindness, respect and compassion, with new prompts, C1.3 which again refers to the Equality Act and C1.6 which relates to the behaviour of the staff team.

There are several changes in KLOE 2, which deals with people being involved in decisions about their care as much as possible, and ensuring staff are trained to understand people’s needs and involve support and social networks.

The new prompt C2.1, which came from the consultation, asks how staff recognise and facilitate people receiving support from other parties, such as carers and advocates. C2.2 relates to advising people of organisations that can provide independent supporting and advice and support use of such services. C2.3 is an interesting new prompt in that it specifically asks about staff having time, training and support to provide care and support in a compassionate and personal way.

KLOE 3 relates to people’s privacy, with prompt C3.3 directly referencing the Data Protection Act, which will be superseded by GDPR. Other aspects of KLOE 3 refer to the Equality Act again and deal with supporting people to be independent, look at preferences, needs and more when scheduling staff. The final new prompt in this section, 3.7, relates to young adults’ choice and flexibility over privacy about parental involvement in their care and support after moving into services.

The main areas of change in the Caring category relate to individual choice, transparency and involving third parties, whilst ensuring that information is managed correctly.

Responsive

The Responsive category starts by asking about how people receive personalised care that is responsive to their needs.

New prompt, R1.6 specifically asks again about technology’s role in supporting people and how easy that technology is to use.

KLOE 2 refers to complaints, and contains themes of making the complaints process accessible, learning from mistakes, working transparently and supporting people to complain. There is one new prompt, R2.4, which involves protecting people from discrimination when complaining.

KLOE 3 refers to end of life. It has moved to Responsive from Caring and has changes to all questions plus three new questions. The changed questions relate to personal choice, involving families and other carers, and pain and symptom management.

R3.4 is a new prompt and looks at identifying when people are reaching their last days and ensuring that changing care needs are dealt with rapidly.

R3.5 is also new and relates to how families, other clients and staff are supported when someone dies.

The final new prompt in this section, R3.6 asks about arrangements for the body of the person who has died, taking into account cultural sensitivity and dignity.

Key aspects of these changes are personalisation, choice and sharing. Meeting these will either require a focus on record keeping, or looking at some of the electronic systems that provide more responsive care records without increasing the burden on administration. Sharing can be achieved very easily with electronic records, although it is important to ensure they conform to GDPR.

Well-led

The final category is Well-led and it starts with a KLOE around having a strategy for high-quality, person-centred and inclusive care. It has six new prompts: W1.2, W1.3, W1.4, W1.5, W1.9 and W1.10.

W1.2 asks ‘How does the service promote and support fairness, transparency and an open culture for staff?’. This came from the consultation and has a clear focus on transparency again.

W1.3 looks at how managers support their staff, and whether they are motivated, caring and open.

W1.4 explores honesty and transparency following an incident, which again points towards transparency and learning from mistakes.

Finally, W1.5 asks whether leaders are suitable, with a specific mention of having integrity.
The remaining new prompts, W1.9 and W1.10 focus on workforce inclusion and equality, along with supportive and collaborative working relationships.

KLOE 2 focuses on governance and the new question, W2.8 specifically relates to security and sharing of confidential data, which again points towards GDPR, but also transparency.
KLOE 3 is about engaging and involving service users, the public and staff. New prompt, W3.5 is aimed at gathering people’s views to shape the service.

KLOE 4 involves learning and innovating for sustainability, with new prompt W4.6 specifically addressing technology, and how this can be used to monitor and improve the quality of care.

Finally, KLOE 5 involves working with other agencies, with the new prompt W5.2 asking about sharing information and assessments with other agencies, and specifically mentioning that this should be ‘for the benefit of people who use the service.’

The new social care KLOEs

It is clear that there are themes running through the new social care KLOEs. There is a focus on using innovative technology with an expectation that this will help to achieve responsive and personalised record keeping, and managing and sharing information securely.

There are other areas which might require a change in approach or attitude for some, for example freedom of choice, openness and engaging more with people’s families and friends. However, for a service that is aspiring to be Good or Outstanding, these should be a given.

The effects of these changes on the sector will only be known in due course, but the future of adult social care looks like it will have more transparency, innovation, personalisation and technology.

Jonathan Papworth is Co-Director of Person Centred Software. Email: j.papworth@personcentredsoftware.com Twitter: @PersonCentredSW 

Are you up-to-date on the new KLOEs? CMM subscribers can sign-in to access the updated document.

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