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British Geriatrics Society Submission to the Department of Health on a Code of Practice on the Prevention and Control of Infection in Care Homes
The Society is delighted to be given the opportunity to contribute to this debate.
Is it clear where The Code of Practice on the Prevention and Control of Infections (Code) sits in relationship to the overarching legislation of The Health and Social Care Act 2008?
Are the terms used to describe those who deliver care in the health care and adult social care settings sufficiently clearly defined within Appendix 2: Definitions?
Is the extent of their roles clear?
Is the language used throughout the Code and its related guidance sufficiently clear and appropriate to those who will be implementing the Code of practice?
Are there any areas where you feel complying with the Code will require a significant change of practice?
Major requirement/undertaking for all relevant staff to have training and supervision in measures required to prevent and control infection. Also major change needed in availability of liquid soap, hand washing facilities and alcohol hand rubs in care homes (in particular).
Currently there is a requirement in hospitals for hand washing/using alcohol rubs. How are we going to audit practice in care homes where there are less resources.
There is some concern that too much use of soap (if you see 30 patients a day you will be required to wash hands 30 times a day) may have adverse effects on at least some skins, There will be a need to use a high quality soap with moisturizers and/or appropriate moisturising cream thereafter which will need to be provided by care homes and generate additional costs.
Would there be any advantages in having two distinct Codes (one for health care and one for adult social care)?
No. One code provides clarity and promotes consistency, particularly important for when service users are transferred between health and social care facilities.
Is the required level of proportionality sufficiently clear within the Code and its related guidance so that the standards already achieved within the NHS are maintained and improved?
Is the required level of proportionality sufficiently clear within the Code and its related guidance so that all parts of the health care system, both independent and NHS, will need to achieve the same standards of care as outlined within The Code of Practice?
However, it would be better that the responsibility for immunisation practice is with the NHS, specifically with primary care as part of whatever local care arrangements exist (or will need to be created). The care provider's responsibility could include making provision for the immunisation to happen etc, but, and most specifically in care homes without nursing, this is not an appropriate task for the manager.
Is the required level of proportionality sufficiently clear within the Code and its related guidance so that where care is delivered in either a residential environment or within the persons own home no undue burden is placed upon the provider of care?
Do Table1 (The application of the Code or Practice to regulated activities) and Table 3 (Policies appropriate to regulated activities) in Appendix 3 provide suitable guidance as to the application of the Code and policies required to the different regulated activities?
Does Table 2 in Appendix 3 give sufficient practical guidance for providers of care on the available sources of advice on infection prevention and control?
Yes. However this needs to be made clear at local level. For example, a designated site lead at a small residential home, will need to know who and how they are to obtain local support from PCT infection control team.
Do you feel that the Code will reinforce the requirement of providers to offer immunisation to staff?
Yes but needs to be more specific – see below
Do you think this will lead to increased vaccine uptake?
No. For example there is no emphasis on provision of annual influenza vaccinations in the code of practice( although we note this is mentioned in prevention and control of infection in care homes documentation).
Does the Impact Assessment accurately represent the costs and benefits associated with implementing the Code and its related guidance?
Not clear if the current costing includes training and education of all relevant staff in infection and prevention and control (e.g. hand hygiene, asepsis). Does the cost cover upgrading hand washing and isolation facilities etc?
Do you have any relevant data that help us improve our economic assessments?
Are there any proposals contained in the Code and its related guidance that might have an adverse impact on race, disability, gender, sexual orientation, religion, belief, or age equality for you or for service users?
Will this practical information for care homes help you deliver your service by acting as a ‘how to manual’?
Does this practical information provide an appropriate level of detail?
Are the templates in this practical information for care homes useful?
Are there additional templates that would be useful?
What else in this practical information for care homes would be useful?
Links to electronic resources for staff education e.g. NPSA hand hygiene video
Professor Graham Mulley
For and on behalf of British Geriatrics Society
Prepared for the BGS by Dr Alison Cracknell, BGS Lead for Patient Safety and member of BGS Primary and Continuing Care Special Interest Group
The British Geriatrics Society
The British Geriatrics Society (BGS) is the only professional association, in the United Kingdom, for doctors practising geriatric medicine. The 2,500 members worldwide are consultants in geriatric medicine, the psychiatry of old age, public health medicine, general practitioners, nurses, allied health professionals, and scientists engaged in the research of age-related disease. The Society offers specialist medical expertise in the whole range of health care needs of older people, from acute hospital care to high quality long-term care in the community.
Geriatric Medicine (Geriatrics) is that branch of general medicine concerned with the clinical, preventive, remedial and social aspects of illness of older people. Their high morbidity rates, different patterns of disease presentation, slower response to treatment and requirements for social support, call for special medical skills. The purpose is to restore an ill and disabled person to a level of maximum ability and, wherever possible, return the person to an independent life at home.