Safeguarding adults at risk should be integrated into existing practice systems and processes for delivering care.
We will review this topic of safeguarding when we review the ‘safe’ key question. This relates to Regulation 13: Safeguarding service users from abuse and improper treatment.
Everyone who comes into contact with children and young adults at risk using health and care services have a responsibility to safeguard them from suffering any form of abuse or improper treatment while receiving care.
Part of our statutory duties to protect and promote the health, safety and welfare of people who use health and social care services. Risks to children and young adults using services are higher where systems and processes are weak and staff are not clear or do not know what to do when a safeguarding situation presents.
On inspection we will check what systems and processes are in place and how robust they are.
What to expect on inspection
When we inspect we need to see that all practice staff can demonstrate their competence in safeguarding adults at risk. They need to:
- demonstrate their understanding of the definition of an adult at risk and the types of abuse they may be subject to
- show awareness of the internal arrangements for recording a safeguarding adult concern and how this is included within the practice’s safeguarding adults policy
- show awareness of the external process for reporting the concern and how this is in line with local multi-agency policies and procedures.
Each practice should have a designated lead for safeguarding adults at risk. They should be aware of the respective safeguarding adults leads within the local clinical commissioning group (CCG) and the local authority safeguarding adults team.
We need to see evidence that:
- the practice gives sufficient priority to safeguarding adults at risk
- staff take a proactive approach to safeguarding and focus on prevention and early identification
- staff take steps to protect people where there are known risks, respond appropriately to any signs or allegations of abuse, and work effectively with other organisations to implement protection plans
- there is active and appropriate engagement in local safeguarding procedures, and effective work with other relevant organisations
Legislation and guidance
The Care Act (2014) clarifies expectations about safeguarding adults training.
Staff induction training should include awareness of how to identify an adult at risk of actual or potential abuse and how to report it. The Act requires safeguarding adults boards to make sure they work with their relevant partners, including CCGs, to provide this training. Practices must make sure that all staff have the appropriate level of competence for their role. Formal face-to-face training is one way that practice staff can develop their knowledge.
The Act notes that staff governed by professional regulation should understand how their professional standards and requirements underpin their roles to prevent, recognise and respond to abuse and neglect:
For registered dental professionals, the General Dental Council (GDC) Standards for the dental team (2013), stresses the need to raise concerns if patients are at risk.
Intercollegiate guidance
Intercollegiate guidance Adult Safeguarding: Roles and Competencies for Health Care Staff was published in August 2018. This sets out:
- A framework to support practitioners, employers and commissioners to understand the role and level of education and competence awareness for specific roles/job purposes.
- The minimum training requirements staff should complete. It acknowledges that not all staff will be able to access the training within the first year of publication, but expects that staff will be trained to achieve the appropriate competencies by 2021.
Competency framework
The competency framework set out in the intercollegiate guidance specifies 6 levels/competencies:
- Level 1: for all non-clinical staff. For example receptionists and practice managers.
- Level 2: for all dentists and dental care professionals.
- Level 3: for community or hospital dentists working with vulnerable patients. This is not normally needed for dentists and dental care professionals working in general dental practice although staff acting as a safeguarding lead may wish to consider undertaking this level of training.
This guidance states that safeguarding training should be refreshed every three years. Level 1 and Level 2 training refresher can be done online. Level 1 training should last a minimum of two hours, level 2 a minimum of three hours.
Staff are not restricted to the minimum level of training identified as appropriate for their role. Practices may choose to offer a higher level of safeguarding training for some or all staff.
Notifying CQC of safeguarding incidents
Not all referrals the practice makes to the local authority need to be notified to CQC. Practices are only required to notify CQC of safeguarding incidents where the allegation of abuse is linked to their provision of care.
Example 1
Ms L visits for a routine checkup. The dentist notices bruising on her cheek. She says that her partner has hit her.
Is statutory notification to CQC required?
No. It is not alleged that the abuse relates to the doctor carrying on his regulated activity. However, the dentist must follow his practice’s normal processes for safeguarding adults and domestic abuse.
Example 2
Patient G, an older patient with dementia, attends the practice and needs an injection. On seeing the needle, she becomes highly agitated. The nurse attempts to calm the patient, but when that fails, forcibly restrains her to allow the injection. Patient G’s arm is bruised. Her son makes a formal complaint to the practice manager.
Is statutory notification to CQC required?
Yes. It is alleged that the abuse was committed by a member of staff at the practice during the carrying on of a regulated activity. You should notify us even if the abuse is alleged and not yet proven to have taken place.
You must notify us as soon as possible.