Thanks for all the feedback about last week’s post around handling complaints and potential ways you can overcome any possible challenges. This week, I wanted to give some consideration to another topic that often comes up in the Lead to Succeed (L2S) workshops we deliver – Mandatory Training…
Leading and Managing the Inspection Process (the fifth module of L2S) includes an activity called “Potential Sources of Information for the KLOEs”; this is great for getting people thinking about the many types of evidence available to show the inspector why you are outstanding (think of the sources of evidence document as a starting point which you can add examples and relevant evidence specific to your setting). It is always encouraging to see the long lists of sources of evidence, but the one that always seems to be top of the list is the training matrix. Here’s why…
If you have been in the Social Care sector for a while, you will remember as I do when the inspection body was CSCI, (the previous name for CQC – see below) for which some of our L2S facilitators were inspectors; I’m therefore drawing on their experience as part of this blog. A CSCI inspection was very focussed on whether or not people were trained and up-to-date, mainly because the training and its frequency were stipulated in the legislation.
When CSCI became CQC, both the inspection process and legislation changed via the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, to be precise, which changed the emphasis to “Competence”. Those of you who know the regulations will know that regulations 5 and 19 “fit and proper persons” include: providers only employ ‘fit and proper’ staff who are able to provide care and treatment appropriate to their role and to enable them to provide the regulated activity.
Going back to that activity in module 5, why is the training matrix still the first thing that appears in the sources of evidence activity? It was probably the first thing during the CSCI days to be asked for, yet CQC inspectors spend much more time observing what is actually happening in practice (you will recall we talked about SOFI in an earlier post.) Managers who complete L2S with us regularly share that inspectors have arrived at 6.30am and talked to the staff finishing the night shift; have arrived at lunchtime and had lunch with the residents; and, have been on visits with staff in domiciliary settings. This is very different from the previous paper-based, mostly office-based, version of inspection, although occasional stories of inspectors staying in the office and not carrying out observations still circulate.
To achieve outstanding in this area, we recommend that you evidence to CQC and possibly your commissioners and internal auditors, that not only have staff been trained, but also the learning journey you have taken them on and how they continuously improve and learn on an on-going basis. You all know the expression “you learn something new every day” or “every day is a school day”. The most important aspect of any kind of training is that they are putting what they have learned into practice, every day with the people they support. Otherwise, what is the point in investing time, money and effort into training?
Training is only a piece of the jigsaw as the learning that happens as part of that process is much more important and the competence that follows is even more important, which is why in the recent Skills for Care publication “Mandatory Training”, it clearly recommends that “knowledge and competence should be assessed at least annually”. You therefore need to consider what you have in place to capture this crucial piece of the puzzle.
One of the critical pieces of evidence CQC are looking for is that of continuous improvement; just ensuring your training matrix is up-to-date does not achieve this. Making sure every member of staff has had the necessary training to do their job safely sounds like the first step on the journey to meeting the regulations, but given that the regulations also include Regulation 18 which states: “To meet the regulation, providers must provide sufficient numbers of suitably qualified, competent, skilled and experienced staff to meet the needs of the people using the service”, there is much more to it than just being “up-to-date”.
There are many different pieces of evidence that can show why you are outstanding, often demonstrated by the long lists of evidence that managers come up with during the “sources of evidence” activity, proving that the training matrix is just scratching the surface. One great tip is to collect all of those sources of evidence together into a “One Drawer Inspection Kit” (also in module 5 – Lead to Succeed), which is the subject of next week’s blog.