The new National Standards of Healthcare Cleanliness 2021 were released quietly and without a fanfare back in April 2021.

So much so, I wasn’t even aware of them until a few weeks ago when I thought I should start updating the Infection Prevention and Control Policy and its sister document, the Cleaning Standards and Schedule Policy. Additionally, there’s been no traffic on the Practice Index forum about these new standards, so I assumed this was simply a benign update to the previous 2007 standards.

However, I couldn’t have been more wrong! If you haven’t yet seen these standards, I suggest you engage in some bedtime reading.

The standards

These national standards state on page 9 that they “apply to all healthcare settings”; it specifically mentions “primary care”. Good news, I thought, as I’m a real advocate for compliance, and cleanliness is absolutely what our service users would expect.

In the document, there’s an obvious lean towards secondary care from the outset; however, it all reads well and nothing is really that difficult or too traumatic to implement… that is, until about halfway through.

At the chapter that describes Governance, my heckles and blood pressure started to rise. It’s akin to a Quentin Tarantino film where, all of a sudden, it all goes horribly wrong and gets very messy!

Come the next chapter on Auditing, it’s full-blown gore and a true work of fiction. The processes required to implement the standards need a serious amount of time, effort and cost spent on them – all of which are in short supply. Whilst I believe this is doable for a large NHS Trust that has oodles of IPC and cleaning staff, for us in primary care, no chance, not on your nelly!

Sadly, the supporting documents section continues along the same secondary care lines – blah, blah, blah – and is mostly irrelevant. However, both the Compliance Grid and Efficacy Audit have some uses.

Inclusion

When you’ve read the document, I’m sure you’ll agree that it’s written for our NHS collegues in secondary care and this is absolutely apparent come the Acknowledgement section; of the 42 acknowledgments listed as having provided input to these new national standards, not one of them hails from primary care! Should I be shocked? Well, no, because we’re used to it; we clearly should be branded NHS Fungi as we’re so often kept in the dark.

However, we must become compliant as these standards have been adopted by the CQC, and GP Mythbuster 99 on infection control has recently been updated and says we must adhere to these standards and they’ll expect to see how we audit and give ourselves starred ratings.

So, when we’re being inspected, maybe we mushrooms should ask our regulator if NHS England would pass their ‘Responsive’ question as, at the moment, I don’t feel very included!

IGPM to the rescue!

Over the past week, I’ve spoken to several PMs and also the Institute of General Practice Management (IGPM). It seems that all of us were equally bemused as none of us were aware of this very important document. As such, I asked if the IGPM could assist.

Nicola Davies, a PM, a friend of Practice Index and a Director at IGPM, was instrumental in raising this with NHSE. She questioned how this had been imposed without any apparent thought for primary care.

In their defence, NHS England promptly advised that:

• A large GP practice took part in the pilot in 2018
• The GP provider network was involved in the development process
• The document went to consultation in 2019 and was sent to all organisations and professional associations including CCGs, and comments were received and noted
• A number of webinars to support the primary care sector were provided

Well, that passed me by – as it did everyone I’ve asked!

I assume that this also passed by the c.15k members who support the wonderful PI forum, as had there been any significant concerns, this forum would have been ablaze with comments such as “Please help!” … but there simply hasn’t been a whisper.

Good news

NHSE have engaged with the concerns raised and have agreed to discuss the next steps with IGPM. They also advised that they’re in discussion with a “number of CCGs and the network of GPs to revise documentation to be more user friendly for primary care, and new cleanliness charters have just been uploaded to support this sector”.

Asking Nicola Davies for a comment to support this blog, she said, “We’re frustrated that a document of this weight comes out in such a way as to feel that it’s under our radar, and again we don’t appear to have been involved in the working party. 

NHSE has been very quick to engage with IGPM and we’re hoping that this will lead to further developments within the document that will make it a simpler, less onerous task.”

Next steps

Members of Practice Index can help by adding a comment to this post here. It would be very useful if you could let us know if you were advised of these changes or not, and if so, how? Was it NHSE, via one of their webinars, or were you given instructions from your CCG?

Any thoughts/comments will be used as evidence at the IGPM meeting.

Lastly, please note that whilst the IPC Policy is now live on PLUS with numerous updates, it now includes both PPE and IPC statement policies. We are currently working to update our Cleaning Standards and Schedule Policy to incorporate all of the changes and this will be available very soon.

As to how we audit these standards… well, stand by to stand by, as this will need to be a new chapter added at a later stage once those in the NHSE filmset work to make this more user friendly for those in primary care and provide us with some useful guidance, as opposed to how we can clean a bedpan!

Personally, I’d suggest reading and implementing the standards as soon as possible.

For governance purposes, audit and use the NHS Compliance Grid as a tool, and if you wish to implement the full audit process as detailed, go for it, but this may be changing for GP practices soon.

Keep smiling, clocks go back next month!

Mat

Update – the new policy is now available here [PLUS]