Bhavna Keane-Rao, Managing Director, BKR Consultancy
Throughout the COVID-19 pandemic we have received a small number of calls from providers wanting assurance their COVID plans were robust, or to review critical incidents, with a substantial increase in recent weeks. Many of the calls now received are focused on reviewing critical incidents, either large outbreaks or death(s) that have occurred due to COVID.
It is often found, when reviewing these events, that there was a failure to maintain appropriate records. This was further complicated by the swift pace the epidemic took hold; the number of staff needing to self-isolate; the increase management of staff concerns; the rapidly changing guidance as well as the resource additional telephone calls and video visits with families. The statutory bodies, such as coroners and police, when reviewing these events were unlikely to appreciate the huge impact COVID had on systems that were primarily designed to simply support people caring for people. How well a service managed the pandemic is assessed remotely through records, staff accounts, policies and procedures, decisions and processes.
With regulators restarting inspections, and families again starting to visit, it is important that services are able to demonstrate how they minimised and managed the outbreak of COVID.
As part of this management programme services should be maintaining both a service user and staff log of potential COVID symptoms. This should include the date symptoms first presented, the type of symptoms, the dates and outcomes of tests.
The service should also ensure that all service users have a COVID care plan that outlines how contact with the family is to be maintained, whether they agree to swab testing, the frequency of testing and how often care plans are to be updated where COVID symptoms are present.
Existing policies and procedures such as infection control, outbreak management and health and safety policies should be updated. The policies and procedures regarding visitors as well as the appropriate use of PPE should also be updated. In addition, the service would need to develop Standard Operating Procedures (SOP) for the use of PPE, the management external contractors, health and social care support services and family visits. SOPs may also be useful in supporting staff in testing processes and procedures.
To evidence that staff are keeping pace with the developing situation when government, PHE or CQC guidance is issued this should be made immediately available to staff along with a read and sign sheet. Updated guidance should be removed and filed for future reference. There are examples of services being judged on decisions made a month, or more, earlier on the current understanding of the virus. The early guidance is key in explaining the reasons earlier decisions were made.
Although it may be possible to complete these activities retrospectively this is a riskier strategy. Staff memories fade, staff leave and for others their recollection of events may differ. It may be difficult to convince regulatory bodies that these non-contemporaneous records are a true reflection of the actions taken. The motive for creating records after the events is likely to raise suspicions.
There is also a need for accurate recording as the current testing regime within care homes appears hit and miss. It has been reported by some care services that, on occasion, tests have not been collected making it impossible to comply with the current weekly testing guidelines.
Families, and other partners in care, have on the whole remained supportive of care services despite the restricting of service user contact. This, however, may change as professional and family visits increase bringing increased scrutiny of the decision-making process. There remains the threat that families seek legal redress where it is felt services have acted disproportionately to the perceived risk.