Soul Care Aesthetics is operated by Soul Care Aesthetics Ltd. The service sees patients on a day case basis only, therefore no overnight facilities are present. Facilities include five consulting rooms for aesthetic procedures; one of which is designated for cosmetic surgery.

The service provides cosmetic surgery for patients over the age of 18; although it offers non-regulated procedures to young people aged 16 to 18. We inspected surgery as a core service.

We inspected the service using our comprehensive inspection methodology on 18 January 2018. This identified the provider was in breach of Regulation 12 (safe care and treatment) of the Health and Social Care Act 2008 (Regulated Activity) Regulations 2014. The full report of this inspection can be found on the CQC website: https://www.cqc.org.uk/location/1-3150959664

We carried out a focused inspection on 8 November 2018, to follow-up our concerns.

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.

At this inspection we looked mainly at the safe key question and specific sections of the effective and well led key question.

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 rate

Whilst we now have powers to rate cosmetic surgery services, as this was a focused inspection, we have not rated the service. We inspected, but did not rate, elements of safe, effective and well led.

We found the following areas of good practice:

• Staff generally understood how to protect patients from abuse and the service worked well with other agencies to do so. Staff had training on how to recognise and report abuse and they knew how to apply it.

• The service controlled infection risk well. Staff kept themselves, equipment and the premises clean. They used control measures to prevent the spread of infection.

• Staff completed and updated risk assessments for each patient.

• The service had suitable premises and equipment and looked after them well.

• The service followed best practice when prescribing, giving, recording and storing medicines.

• The service provided care and treatment based on national guidance and evidence of its effectiveness.

• The service generally had good systems to identify risks and planned to eliminate or reduce them.

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

• There were some minor omissions within the patient records which were not identified during the subsequent audit of the records undertaken by the service.

• Information was not readily available to signpost staff how to make safeguarding referrals when required.

We found the service was now complying with the regulations. We told the provider that it should make other improvements, even though a regulation had not been breached, to help the service improve. Details are at the end of the report.

Amanda Stanford

Deputy Chief Inspector of Hospitals (Central)

Soul Care Aesthetics is operated by Soul Care Aesthetics Ltd. The service sees patients on a day case basis only, therefore no overnight facilities were present. Facilities included five consulting rooms for aesthetic procedures; one of which was designated to be used for cosmetic surgery.

The service provided cosmetic surgery for patients over the age of 18; although did offer non-regulated procedures to young people aged 16 to 18. We inspected surgery as a core service.

We inspected this service using our comprehensive inspection methodology. We carried out the announced part of the inspection on 18 January 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 cosmetic surgery services 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:

• Staff used tools to promote safer practice such as the National Early Warning Score (NEWS) system to conduct observations. Therefore, any deterioration in health could be easily identified.

• Staffing levels were appropriate for the procedures being provided. Staff were 100% compliant with mandatory training.

• A cleaning system was embedded; a deep clean was conducted weekly and daily equipment cleans were done. We saw the use of stickers identifying the date of cleaning, and the name of the individual completing the cleaning therefore ensuring dirty equipment was not used.

• Surgical instruments were decontaminated where necessary in line with infection prevention guidelines.

• All surgical patients received a post-surgery consultation approximately one week after their procedure. In addition, follow up appointments were offered as part of the overall cost for up to a year. This was to ensure the patient’s outcomes were successful and enable early identification of problems.

• Staff followed national standards in line with Professional Standards for Cosmetic Surgeons. Where relevant, National Institute of Health and Care Excellence (NICE) guidelines were also followed.

• A transparent approach was taken to providing information about surgical procedures, including the risks and financial cost of surgery. Therefore, patients were able to give informed consent.

• A flexible approach was taken to enabling patients to choose appointment times to suit them. Although the clinic was shut on Sundays, the staff were open to book appointments for surgical procedures on Sundays if a patient specifically requested this.

• The team who worked at the clinic were a small and cohesive team who engaged in staff and governance meetings.

• Public and patient engagement was actively conducted through social media sites and seeking patient feedback.

• Staff at the clinic were conducting clinical trials in order to develop the service.

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

• Staff were conducting World Health Organisation safer surgery checklists for surgical procedures; however we noted that out of five records, one did not have a checklist. Also not all other checklists were completed fully.

• The service followed Health Technical Memorandum 01-05 ‘decontamination in primary care dental practices’ rather than Health Technical Memorandum (HTM) 01-01 ‘decontamination of surgical instruments’. Despite not formally following a policy which promoted the use of HTM 01-01 best practice guidelines; the service was following all requirements which the exception of protein testing which was in the process of being set up.

• The service used a portable ventilation system to ensure air was free from contaminants rather than an inbuilt system. This was due to constraints of the current location and was due to be rectified when the service moved premises later in 2018.

• At the time of the inspection, the clinic were not submitting data to the Private Healthcare Information Network (PHIN) as part of legal requirements regulated by the Competition Markets Authority (CMA). However, we acknowledge this is a relatively recent legal requirement with providers being asked to initially submit this data over a five year phase which ends in 2020.

• We saw that medicines were held securely and there was a process of escalation should the fridge temperatures be out of range which was to use the alternative medicines fridge held on the premises. In addition, the ambient room temperature for areas in which medicines were stored was not routinely recorded.

• Although staff had completed safeguarding adults training; training on safeguarding children had not been undertaken by all staff. However, the consultant surgeon and clinic manager had both received training in this area. The safeguarding policy did not include a full list of up to date situations in which patients might experience abuse. For example female genital mutilation.

• The service had a risk register was in place, with one risk recorded. However, we identified other potential risks which may have benefitted from being added to the risk register. For example, the clinical waste bin, although kept locked, was not secure due to not being a designated bin for this purpose.

• Although the service demonstrated a good working relationship with local pharmacists; there was no formal service level agreement.

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 two requirement notices that affected surgery.

Action the provider MUST take to meet the regulations:

• The provider must ensure that the World Health Organisation safer surgery checklist is appropriately completed for each patient undergoing a surgical procedure.

• The provider must ensure they have a local decontamination policy which follows best practice guidelines ‘decontamination of surgical instruments’.

Action the provider SHOULD take to improve:

• The provider should ensure all staff have an up to date awareness of child safeguarding.

• The provider should ensure the safeguarding policy contains information regarding all types of abuse such as female genital mutilation, modern slavery and the risk of being radicalised.

• The provider should consider the process of submitting data to the Private Healthcare Information Network (PHIN) by 2020 as part of legal requirements regulated by the Competition Markets Authority (CMA).

• The provider should develop a process by which staff members making entries into the medicine fridge temperature log book can be identified. Also, ambient room temperatures should be routinely recorded as per the medicines policy.

• The provider should ensure all potential risks to the service are recorded on the risk register, and all incidents are recorded in order to enable shared learning and appropriate action plans.

• The provider should address the security of the clinical waste bin.

• The provider should develop a service level agreement with pharmacists to formalise current arrangements.

Heidi Smoult

Deputy Chief Inspector of Hospitals (Central)