132 Harley Street Limited

Updated 29 March 2024

132 Harley Street Ltd is a consultant outpatient facility at 132 Harley Street, London, W1G 7JX and provides private outpatient diagnostic and treatment services to adults. The main speciality is gynaecology. The service provides consultation rooms as well as outpatient pathology services and colposcopy. It also offers ultrasound service as well as urodynamics testing.

The service rents consulting rooms to a variety of conventional specialists as well as complementary therapists. The specialists are all registered with the General Medical Council and all offer consultations at the clinic, as well as working in hospitals. The patients are required to pay consultants individually for consultation and treatment. There are no practising privileges arrangements.

132 Harley Street Limited occupies part of a building managed by an estate management company. The service is located across five floors, with clinical rooms on the ground floor and two upper floors. Services are available to any fee-paying patient. The service is open Monday to Friday 8.30am to 5.30pm. The service is not open at the weekends. The service is led by two directors who are both NHS consultants, Mr J Richard Smith and Mr Michael K Stafford. The service manager is the registered manager. They are supported by a clinic nurse, healthcare assistant, practice personal assistant and receptionist.

The location is registered with the CQC to provide the following regulated activities; treatment of disease, disorder or injury and diagnostic and screening procedures and family planning. The service carries out diagnostic colposcopy (biopsy of the cervix) procedures. The provider told us that no hysteroscopy, cautery or cryotherapy procedures are carried out at the service.

How we inspected this service

Throughout the pandemic CQC has continued to regulate and respond to risk. However, taking into account the circumstances arising as a result of the pandemic, and in order to reduce risk, we have conducted our inspections differently.

This inspection was carried out in a way which enabled us to spend a minimum amount of time on site. This was with consent from the provider and in line with all data protection and information governance requirements.

We carried out an announced comprehensive inspection at132 Harley Street Limited on 20 September 2023. Our inspection team was led by a CQC Lead Inspector. Before visiting, we looked at a range of information that we hold about the service. We reviewed information submitted by the service in response to our provider information request. During our visit we interviewed staff, observed practice and reviewed documents.

To get to the heart of patients’ experiences of care and treatment, we always ask the following five questions:

• Is it safe?
• Is it effective?
• Is it caring?
• Is it responsive to people’s needs?
• Is it well-led?

These questions therefore formed the framework for the areas we looked at during the inspection.

Updated 29 March 2024

This service is rated as Requires improvement overall. (Previous inspection August 2013 unrated).

The key questions are rated as:

Are services safe? – Requires improvement

Are services effective? – Requires improvement

Are services caring? – Good

Are services responsive? – Good

Are services well-led? – Requires improvement

We carried out an announced comprehensive inspection at 132 Harley Street Limited as part of our inspection programme, to check whether the service was meeting the legal requirements and regulations associated with the Health and Social Care Act 2008. This was a first rated inspection for the service that was registered with the Care Quality Commission (CQC) in August 2020. During this inspection we inspected the safe, effective, caring, responsive and well-led key questions.

The service was previously inspected in August 2013, and we found it was providing care in accordance with the relevant regulations. At the time of inspecting this service in 2013, CQC did not have the statutory powers to rate the service.

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 exemptions from regulation by CQC which relate to particular types of regulated activities and services and these are set out in Schedule 1 and Schedule 2 of The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.

The service manager 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:

• There were some internal risk assessment processes, but these did not always function well and were inconsistent in their implementation and impact.
• There was evidence some safety risks were assessed however, this was not always well-managed; the service did not have an effective system of health and safety checks. For example, there was no evidence of control measures to identify risks from exposure to Legionella.
• There were safe procedures for managing medical emergencies including access to emergency medicines and equipment.
• The service did not manage medicines appropriately. For example, prescription stationery was not always stored securely, in line with recommendations.
• Records were written and managed in a way that keep people safe. Staff helped patients to be involved in decisions about their care and treatment.
• Patients were treated with kindness, respect and compassion. Feedback from patients was positive about the way staff treat people.
• The service had a complaint policy and procedures in place. We found that complaints were dealt with in a timely manner and with openness and transparency.
• The provider had quality improvement processes in place. We saw staff had completed audits to monitor quality and improve outcomes for patients.
• Staff whose files we reviewed had not completed all essential training at an appropriate level.
• The processes for providing all staff at every level with the development they need, required improvement. Some staff had not received an annual appraisal in the last year. There was no effective system of documenting staff appraisals.
• Staff involved and treated people with compassion, kindness, dignity and respect.
• Patients could access care and treatment from the service within an appropriate timescale for their needs.
• Staff said that they felt happy to raise concerns or issues to the provider.
• The way the practice was led and managed promoted the delivery of high-quality, person-centre care. However, the governance arrangements in place were not effective, there were some areas where control measures had been put in place to manage risk, but leaders did not have oversight.

The areas where the provider must make improvements as they are in breach of regulations are:

• 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.

We spoke to the provider about the concerns identified and the risk to people’s safety and wellbeing. Under Regulation 17(3)(a)(b) of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, we asked the provider to send us a report on actions they planned to take to meet the associated HSCA regulations. The impact of our concerns is minor for patients using the service, in terms of the quality and safety of clinical care. The likelihood of this occurring in the future is low once it has been put right.

We have told the provider to take action (see specific details of this action in the Requirement Notices at the end of this report).

The areas where the provider should make improvements are:

• Improve the facilities in place for people with visual and hearing impairments.
• Establish protocols for verifying the identity of patients.
• Take action to review the appraisal policy to ensure all staff have an annual appraisal.

Dr Sean O’Kelly BSc MB ChB MSc DCH FRCA

Chief Inspector of Health Care