24 and 26 July 2017
During a routine inspection
Marie Stopes International (MSI) Sandwell is operated by Marie Stopes International. MSI Sandwell was registered with the Care Quality Commission (CQC) in October 2010. The MSI Sandwell location holds a licence from the Department of Health (DH) to undertake termination of pregnancy services in accordance with The Abortion Act 1967.
Sandwell location provides medical and surgical abortion, contraception, face-to-face counselling, and screening for sexually transmitted infections. Services are provided to NHS-funded patients referred by local clinical commissioning groups, as well as private patients.
Facilities at the MSI Sandwell location include a surgical treatment room, a room used for recovery and preparation, and a consulting room. Patients waited in the shared waiting area until called through for consultation, after this they waited in a small waiting area outside the main treatment room.
We inspected this service using our comprehensive inspection methodology. We carried out the unannounced part of the inspection on 24 July 2017, along with a short notice announced visit on 26 July 2017.
We observed activity, including staff interaction with patients, and He checked the environment and equipment. We spoke with two medical staff on the five nursing staff, two reception staff, and two managers .We reviewed 28 sets of records and spoke with five patients. Before and after the inspection we reviewed information about MSI Sandwell.
To get to the heart of patients’ experiences of care and treatment, we ask the same five questions of all services: are they safe, effective, caring, responsive to people's needs, and well led.
Throughout the inspection, we took account of what people told us and how the provider understood and complied with the Mental Capacity Act 2005.
Services we do not rate
We regulate termination of pregnancy services but at the time of the inspection we did not have a legal duty to rate them when they are provided as a single specialty service. We highlight good practice and issues that service providers need to improve and take regulatory action as necessary.
We found the following issues that the service provider needs to improve:
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Out of 16 Termination of Pregnancy Early Warning Scores (TEWS) forms reviewed, two were completed correctly in accordance with the guidelines for completion of TEWS.
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The provider supplied mandatory training figures, which showed that safeguarding, manual handling, consent, advanced life support; basic life support, incident reporting, medical gases and scanning training did not meet the provider’s own targets. The provider did not offer supervision.
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The provider supplied mandatory training figures for infection prevention and control (IPC), which showed targets for IPC training had not been met by clinical and non-clinical staff. Therefore, we could not be assured that staff were able to apply basic IPC practices.
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Handwashing and the wearing of gloves were variable in the preparation/recovery room and the consultation room.
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The provider told us that medical gases training was provided both electronically and as part of a three day anaesthetic and recovery training course. We saw that 87% of eligible staff had attended the anaesthetic and recovery training course. The training matrix however included medical gas training separately which showed that only 4% of eligible staff had completed it. Therefore, we could not be assured that the training matrix was kept up to date.
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Staff had only checked the major haemorrhage pack once ever.
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The recovery room was small with very little space between patients; this made it difficult for staff to manoeuvre around patients to perform nursing care, and for staff to move the patients’ bed from the treatment room into the recovery room after their procedure.
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Recording of Oromorph (a controlled drug morphine base) was inaccurate, there were no initials on amendments, and there were two different entries within the controlled drug register. Calculation of the remaining Oromorph appeared to show that 100 mls was possibly missing. We raised this at the time of inspection and the provider took immediate action to look into the matter.
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Managers told us that paper held records that were transferred to and from other MSI locations should be taken by courier to ensure their safe and secure delivery. However, staff told us they transported records to and from other MSI locations using a sealed secure bag, then styles. We raised this with the regional director at the time of inspection who said they would take immediate action to ensure staff did not do this.
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On the day of the announced inspection, we found two folders with patients’ identifiable information out on top of the cabinet.
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We saw a patient could not have their surgical procedure on the day due to four patients attending for surgical termination. This was because there was a limitation on the number of people who could be cared for in the preparation /recovery room .There was no risk assessment completed on the day to decide which patient should be cancelled based on gestation. The service could not offer the patient another appointment until 23 weeks gestation. We wrote to the MSI nominated individual and asked for assurance of how the provider ensured these patients were subsequently safely treated, the patient had the procedure carried out within the lawful gestation period.
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We saw one patient who was displaying challenging behaviour towards staff. The provider told us that while they had a policy on conflict resolution this policy did not cover this aspect of behaviour. They planned to address this issue. We noted that only 17% of staff had training in conflict resolution. Therefore, we were not assured that staff were enabled to manage these issues.
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There was no provision of easy read documentation for people with learning disabilities. Staff told us they did not have any training or guidelines on communicating with people with learning disabilities.
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At the time of inspection the clinical operations manager identified three potential areas of risk however, these were not listed on the locations risk register.
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Early opportunities to learn from the March 2017 incident of haemorrhage and delayed emergency transfer to an acute service were missed.
However, we found the following areas of good practice:
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Staff knew how to report incidents and described that they got an email response containing the outcome of the incident investigation.
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The provider had a policy on female genital mutilation (FGM) which was in date. Staff asked patients at the consultation for both medical and surgical termination about this. This was documented on the individual patient safeguarding form. Staff knew to report this to the safeguarding lead and the police if the patient was less than 18 years of age.
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As of 17 August 2017 child sexual exploitation (87%) and PREVENT (88%) training levels met the provider standards of 85%. FGM training level was 84%
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We saw decontamination procedures carried out after each surgical procedure in the treatment room. The provider loaned theatre packs and decontaminated and packaged instruments in accordance with Health Technical Memorandum01-01 decontamination of surgical instruments.
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The staff members who carried out the consultations on the day of the termination checked the electronic record for completeness and accuracy before they took the patient through to wait for their termination.
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Treatment was managed in accordance with the Royal College of Obstetricians and Gynaecologists (RCOG), including gestation limit for the types of treatment provided.
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Anaesthetic arrangements were in accordance with the Royal College of Anaesthetists (RCoA), Association of Anaesthetists of Great Britain, and Ireland (AAGBI).
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We observed staff talking with patients and giving contraception where required.
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Doctors and nurses administered pain relief in line with best practice. For example, staff offered patients nonsteroidal anti-inflammatory drug (NSAIDS) routinely, which is recognised as best practice.
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MSI had implemented a bespoke ultrasound training course to date pregnancy provided by a qualified external sonographer delivered in line with the requirements of MSI policy.
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We saw nurses explained the procedure, possible risks, and alternative options before taking written consent from patients at all times. Nurses asked patients if they wished to continue right up to the point of the termination.
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Staff were supportive and showed empathy when they talked with patients. One patient told us that the nurse held her hand all the way through because she was so nervous about the surgical termination. Another patient who originally went for a medical termination became very upset when she realised that the process would commence at home, was comforted by the nurse, who then discussed changing to a surgical termination, which the patient decided to do.
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At reception, staff were responsive to patients in relation to their identification. The services reception was directly adjacent to the GP service reception, therefore, staff confirmed patients’ identification by using the first name only, and second part of their postcode. They also spoke in a hushed manner and wrote the answers to questions on paper rather than verbalising them if it was sensitive information.
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The MSUK vision that women be in control of their fertility was visible and clear in the clinics information and articulated by staff in all roles who, we found were committed to this.
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The provider organisation had a system in place for checking the registration of nurses and doctors and insurance for practitioners, the operations manager told us they receive a three months’ notice prompt for when they these are due for review.
Following this inspection, we told the provider that it must take some actions to comply with the regulations and that it should make other improvements, even though a regulation had not been breached, to help the service improve. We also issued the provider with one warning notice and four requirement notice(s). Details are at the end of the report.