During our inspection the service did not undertake any planned surgical procedures and this limited the number of people that we were able to speak with. Those we were able to speak with, briefly, told us they had been well informed about what to expect during their initial consultation. They said it had been a stressful time but that staff had treated them with respect, had been professional and had given them comprehensive information to support them in understanding their options.

When we looked at people’s treatment records we found that before they had received any care or treatment their consent had been sought and recorded. We found that the provider had then acted in accordance with their wishes.

There were procedures for receiving, handling, considering and responding to comments and complaints. People who used the service told us that they knew how to raise concerns and were confident that these would be listened to and acted upon. We looked at the complaints policy and procedure. This demonstrated that the organisation was receptive to hearing the views of people who used the service, and acted on them where necessary.

People were protected from the risk of unsafe or inappropriate care and treatment because accurate and appropriate records were maintained by the provider. People's personal records, including medical records, were accurate and fit for purpose and were stored securely.

During our visit we used a number of different methods to help us review the treatment and care being delivered and to capture the views and experiences of the people who used this service. We spoke with two people who were receiving care and support, observed the facilities provided, looked at supporting care documentation and spoke with staff.

People told us that they had received appropriate information, had their needs assessed and that care and treatment had been planned and delivered in line with their individual choices. We asked them about the information they had been given and they confirmed that clear information both verbal and written had been made available to them to assist them in making decisions. We were told that they had been treated with respect by staff who had offered reassurance and support at all stages of their treatment. One person described the service as "fantastic" and "absolutely brilliant". One person said "the staff in theatre were lovely and everything was explained to me".

In this report the name of a registered manager appears who was not in post and not managing the regulatory activities at this location at the time of the inspection. Their name appears because they were still a registered manager on our register at the time. The provider has informed us that an application to register a new registered manager has been submitted to The Care Quality Commission.

We did not speak to people who used this service as part of this review. We looked at a random sample of medical records and spoke with staff. This was to check that current practice ensured that no treatment for the termination of pregnancy was commenced unless two certificated opinions from doctors had been obtained.

BPAS Brighton is operated by The British Pregnancy Advisory Service. The British Pregnancy Advisory Service (BPAS) is a not-for-profit organisation with 44 registered locations and 21 satellite services across the UK. Services are commissioned to provide termination of pregnancy services, support, information, treatment and aftercare for patients seeking help with regulating their fertility and associated sexual health needs. BPAS Brighton is a nurse led service with medical input, which provides early medical abortion (abortion pill), medical abortion and surgical termination treatments. The clinic also provides counselling and tests for sexually transmitted infections (STI) and contraceptive services.

BPAS Brighton has two admissions rooms, one treatment room, one screening room and five consulting rooms. There are also four day care beds used for recovery and discharge. There were four overnight beds, which were not currently in use and the management advised late medical terminations are no longer available at this location.

BPAS Brighton has three outreach satellite clinics, we visited two of these. The satellite clinics provide: medical terminations, counselling, STI screening and contraception.

BPAS Eastbourne undertakes consultations only and has two rooms, one for consultation and one for screening.

BPAS Bognor Regis has two rooms, one for consultation and one for screening and treatments of early medical abortions up to 10 weeks.

Regulation 20 of the Health and Social Care Act 2008 Care Quality Commission (Registration) Regulations 2009 applies to all non NHS bodies that carry out a termination of pregnancy. Regulation 20 sets out the specific legal requirements in relation to termination of pregnancy that must be met. In addition, every independent place where treatment for termination of pregnancy is carried out must be an approved place and is required to follow all (28) of the Department of Health’s Required Standard Operating Procedures (RSOPs).

BPAS Brighton provide the following services

• Pregnancy Testing
• Unplanned Pregnancy Counselling/Consultation
• Medical Abortion
• Surgical Abortion General Anesthetic
• Surgical Abortion Local Anesthetic/conscious Sedation
• Abortion Aftercare
• Miscarriage Management
• Sexually Transmitted Infection Testing and Treatment
• Contraceptive Advice
• Contraception Supply

The main service provided by BPAS Brighton was medical and surgical termination of pregnancies. Where our findings on BPAS Brighton for example, management arrangements – also apply to the satellite services BPAS Eastbourne and BPAS Bognor Regis, we do not repeat the information but cross-refer to BPAS Brighton.

We inspected this service using our comprehensive inspection methodology. We carried out the announced part of the inspection to BPAS Brighton on 06 February 2018 and visited the satellite clinics, BPAS Eastbourne and BPAS Bognor Regis, on 06 and 08 February 2018.

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? Where we have a legal duty to do so we rate services’ performance against each key question as outstanding, good, requires improvement or inadequate.

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, but we do not currently 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 areas of good practice:

• Patients said they were treated with compassion, kindness, dignity and respect.
• Staff told us they considered one of their attributes was being a good team which worked well together. As a team they also worked with other health professionals when needed, to provide a multidisciplinary approach to patient care. Staff were consistent in their view that the best thing about their job was the care they provided for patients.
• BPAS had systems and processes to monitor all incidents and complications and took a positive approach to learning from the location and wider company experiences.
• We saw records which showed that BPAS Brighton staff were monitored to ensure they were in date with the required mandatory training for their role.
• Patients who used the service were protected from the risk of abuse, because the provider had taken reasonable steps to identify the possibility of abuse and prevent abuse from happening.
• Equipment in use was routinely serviced to ensure its safety. We were also told that requests for alternative equipment by the surgeon and staff was considered and provided.
• BPAS had a planned programme of audit and monitored performance monthly using a clinical dashboard.
• The satellite services provided early medical termination services and consultations to the wider rural geography of the area. Every effort was made to support patients to receive treatment in a local/convenient place and ensure that priority was given to later gestational age to ensure treatment was within timescale.
• Patients’ needs were assessed and care and treatment was planned and delivered. Arrangements for those patients with learning disability, or complex needs were available.
• Patients who use the service, their representatives and staff were asked for their views about their care and treatment and their comments were acted on.

However, we also found the following issues that the service provider needs to improve:

• The management of controlled medicines was not consistently safe with some medicines left unsupervised.
• BPAS Brighton did not notify CQC when serious incidents occurred; this is not in line with Regulation 18 of the Health and Social Care Act.
• Records were organised and stored safely at BPAS Brighton, however records for the satellite clinics were not secure at all times and were at risk of compromise to patient confidentiality.
• Systems to summon help were not available in the treatment room and had the potential to place patients at risk.
• Patient confidentiality was not well managed in all areas of the service, with patient list and records left accessible.
• Minimum staffing levels in the treatment room were not locally risk assessed to ensure safety.
• Staff did not have any training to support their role in an emergency with young people. Staff did not receive training to specifically recognise the signs, and act appropriately, if the condition of a young woman aged between 13 and 18 years health starts to deteriorate.
• Staff did not receive additional training to support young women of less than 18 years of age with mental health needs.
• The provider did not ensure that patient group directions (PGDs) for cervical preparation included all relevant information.
• The provider did not monitor or promote review of risks related to multiple visits.
• Staff including the registered manager were not familiar with the Department of Health Required Standard Operating Procedures (RSOP) for termination of pregnancy (2013).

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 four requirement notices. Details are at the end of the report.

Amanda Stanford

Interim Deputy Chief Inspector of Hospitals