We carried out an unannounced comprehensive inspection on 20 February 2017 at the Private Medical Centre - Ealing location 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. We have told the provider to take action (see full details of this action in the Enforcement section at the end of this report).

Are services effective?

We found that this service was not providing effective care in accordance with the relevant regulations. We have told the provider to take action (see full details of this action in the Enforcement section at the end of this report).

Are services caring?

We were unable to assess whether this service was providing caring services in accordance with the relevant regulations.

Are services responsive?

We found no sufficient evidence to rate responsive.

Are services well-led?

We found that this service was not providing well-led care in accordance with the relevant regulations. We have told the provider to take action (see full details of this action in the Enforcement section at the end of this report).

Background

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 clinic was meeting the legal requirements and regulations associated with the Health and Social Care Act 2008.

Private Medical Centre Limited is an independent provider of medical services and treats both adults and children in the London Boroughs of Ealing and Acton. Services are provided primarily to Polish patients. Services are available to people on a pre-bookable appointment basis. The clinic advertises and carries out a variety of other additional services including gynaecology and obstetrics services. However following concerns identified at our inspection we imposed an urgent condition on the provider to prevent the provision of all regulated activities in relation to the medical consultation and treatment services at both the Ealing and Acton sites.

They remain able to provide dental services which were inspected at the same time.

A copy of the full report of the dental service can be found by selecting the ‘all reports’ link for the Private Medical Centre on our website at www.cqc.org.uk.

The Ealing clinic is located on the ground floor of a rented property. The property is leased by the provider and consists of a patient waiting room & reception area, an office, a kitchen and staff room, a medical consultation room, a decontamination room, and two dental and consulting rooms which are all located on the same floor of the property.

Private Medical Centre Ltd is registered as a sole provider with the Care Quality Commission to provide the regulated activities of diagnostic and screening procedures, surgical procedures and treatment of disease, disorder or injury. We did find that the provider was providing gynaecology and obstetrics services that would met the scope to be registered as maternity and midwifery and so the provider would need to apply to register for these when they are able to operate.

At the time of our inspection, the clinic employed three doctors. All three doctors were registered with the GMC with a licence to practise. These clinicians travelled between Poland and England to offer their services. Two of the doctors were providing specialist services in gynaecology and obstetrics and dermatology. Both doctors were not on the General Medical Council (GMC) specialist register. The third doctor was on the UK specialist register for obstetric care.

Other staff at the clinic included three receptionists and the company director. The director, who was the clinical lead, was based at the Ealing location. There was a Polish registered dentist who was registered with the General Dental Council (GDC).

The clinic was open Monday to Saturday from 8:30am to 6:30pm. We were informed that the medical doctors offering gynaecology and obstetrics attended the clinic based on demand and the family doctor was available most of the time.

The provider was not required to offer an out of hours service. Patients who required emergency medical assistance out of operating hours were requested to contact the provider via an emergency phone number and they could speak directly to them. However this telephone was held by the nominated individual who was a dentist but gave medical advice.

Our key findings were:

• Patients were at risk of harm because systems and processes were not in place to keep them safe. Patients were being offered specialist treatment and consultation by doctors who did not have UK specialist training to do so.
• The provider had not ensured that adequate medical indemnity insurance was in place or that appropriate checks of current insurance had been carried out on all clinicians upon commencement of employment.
• Arrangements to safeguard children and vulnerable adults from abuse did not reflect relevant legislation and local requirements.
• The person with overall clinical responsibility had not completed up to date safeguarding training. No records were available to confirm that the other doctors had also received the adequate safeguarding training for their roles.
• There was no system in place for the reporting and investigation of incidents or for sharing lessons learned as a result.
• The clinic had not set up a system to ensure they received medicines alerts or other relevant information from organisations such as the MHRA.

The clinic did not keep medicines safely. We found that some medicines that required to be stored in a fridge were not stored in a fridge. The clinic did not monitor the fridge temperature to ensure that it was within the recommended temperature of between +2 degrees Celsius and +8 degree Celsius.

• The clinic held medicines and life-saving equipment for dealing with medical emergencies. However there were some medicines required for use in emergencies that had expired.
• There was not an effective system in place for obtaining written consent from patients for consultations including those that required intimate examination.
• There was no evidence that staff had received training appropriate to their roles, including update training in infection control, safeguarding and chaperoning.
• Patient outcomes were hard to identify as little or no reference was made to audits or quality improvement.
• The clinic did not have an effective process in place to ensure patients were informed of their results or that a clinical person assessed them.
• Patients who were undergoing consultation including intimate examination and ultra sounds were not offered a chaperone at the time of consultation.
• Information about services and how to complain was available and easy to understand. However complaints received were not fully investigated and no evidence of learning from these was seen.
• The clinic did not hold regular, formal clinical or team meetings.
• There was no formal process in place to ensure all members of staff received an appraisal. The clinic reported they had a responsible officer in place. We did not see how this process fed into the clinic to ensure the person with clinical responsibility had reassurances that the doctors practice was safe.
• The clinic had limited formal governance arrangements in place. The clinic did not have an effective, documented business plan in place.
• The clinic lacked a number of policies and procedures to govern activity.

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

• Ensure that they only deliver services that staff are trained and qualified for.

• Ensure that a system is in place to ensure all clinicians have adequate valid medical indemnity insurance cover and that appropriate checks of clinicians indemnity insurance is carried out upon commencement of employment.
• Ensure there is effective clinical leadership and oversight in place

• Ensure effective governance arrangements are in place to ensure patients receive safe care.
• Ensure that patient safety alerts (including MHRA) are received by the clinic, and then actioned if relevant. Put systems in place to ensure all clinicians are kept up to date with national guidance and guidelines.
• Review the process for obtaining written consent ensuring consent is recorded appropriately and patients sign these forms when consent is required.
• Review chaperone arrangements and policy in particular for gynaecology services, ensuring chaperone training is undertaken by staff who perform chaperone duties.
• Review the process for informing patients of test results including those that are urgent.

On 24 February 2017, the Commission served an urgent notice of decision to impose conditions upon the registration of this service provider in respect of two regulated activities. The following conditions were imposed:

The registered person must not provide medical consultation and treatment services (excluding dental services) under the regulated activity of treatment of disease, disorder or injury and diagnostic and screening procedures to patients without the prior written agreement of the Care Quality Commission from the following locations;

Private Medical Centre – Ealing

124 Uxbridge Road

London

W13 8QS

Private Medical Centre- Acton

1 Eastfields Road

London

W3 0AA