We carried out an announced comprehensive inspection on to ask the service the following key questions; Are services safe, effective, caring, responsive and well-led?

Our findings were:

Are services safe?

We found that this service was not providing safe care in accordance with the relevant regulations.

Are services effective?

We found that this service was not providing effective care in accordance with the relevant regulations

Are services caring?

We found that this service was providing caring services in accordance with the relevant regulations.

Are services responsive?

We found that this service was providing responsive care in accordance with the relevant regulations.

Are services well-led?

We found that this service was not providing well-led care in accordance with the relevant regulations.

We carried out this inspection under Section 60 of the Health and Social Care Act 2008 as part of our regulatory functions. This inspection was planned to check whether the service was meeting the legal requirements and regulations associated with the Health and Social Care Act 2008.

CQC have not inspected this service before. This service was registered by CQC on 7 June 2018. New services are assessed to check they are likely to be safe, effective, caring, responsive and well-led.

The provider, 112 Harley Street, also known as Cooper Health Limited, is registered with the CQC as an organisation providing an independent doctors consulting service to private patients from consulting rooms at 112 Harley Street, London W1G 6HJ. The provider is registered to provide the regulated activities of treatment of disease, disorder or injury and diagnostic and screening procedures.

This service is registered with CQC under the Health and Social Care Act 2008 in respect of some, but not all, of the services it provides. There are some general exemptions from regulation by CQC which relate to particular types of service and these are set out in Schedule 2 of The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. At 112 Harley Street most of the services are provided to patients under arrangements made by their employer with whom the servicer user holds a policy. These types of arrangements are exempt by law from CQC regulation. Therefore, at 112 Harley Street, we were only able to inspect the services which are not arranged for patients by their employers with whom the patient holds a policy.

The director is the registered manager. A registered manager is a person who is registered with the Care Quality Commission to manage the service. Like registered providers, they are ‘registered persons’. Registered persons have legal responsibility for meeting the requirements in the Health and Social Care Act 2008 and associated Regulations about how the service is run.

Our key findings were:

• Staff had received training on safeguarding children and vulnerable adults relevant to their role. They knew how to recognise the signs of abuse and how to report concerns.
• Service leaders had established policies and procedures to ensure safety; however, leaders had not assured themselves that all policies and activities were operating as intended. For example, the service did not have an effective system of health and safety and premises checks. The risk of not having undertaken regular checks had not been assessed.
• The premises were clean and tidy. The provider had undertaken a recent infection prevention and control (IPC) audit but the audit did not include regular legionella audit or cleaning checks.
• Staff involved and treated patients with compassion, kindness, dignity and respect.
• There was a system for recording and acting on adverse events and incidents although it was not clear if these were shared with all staff effectively. Staff told us significant events and incidents were discussed at regular team meetings and recorded, although we were not shown any records of discussions, learning or actions agreed.
• There was no evidence that the service acted on and learned from external safety events including patient safety alerts. The provider did not share safety alerts with staff effectively.
• We found no evidence of quality improvement measures including clinical audits.
• Procedures for managing medical emergencies including access to emergency medicines and equipment were safe.
• Staff had received an annual appraisal but there was no formal system of appraisals which included a review of training needs for staff.
• The clinical record system was not appropriate for the services provided. There was no facility to code patients’ diagnosis and treatment or to put alerts on to the system to support sharing of patient information with other services and clinicians.

We identified regulations that were not being met and the provider must:

• Ensure care and treatment is provided in a safe way to patients.
• Establish effective systems and processes to ensure good governance in accordance with the fundamental standards of care.

You can see full details of the regulations not being met at the end of this report.

There were areas where the provider could make improvements and should:

• Review ways to improve engagement with patients.
• Establish a formal process for verifying a patient’s or responsible adult’s identity.
• Review the need to store children’s pads in the defibrillator.

Professor Steve Field CBE FRCP FFPH FRCGP

Chief Inspector of General Practice