These are my notes and reflections on this week’s Zoom.  As with last week’s session, it was clear that providers are often in novel and difficult situations without any clear guidance.  They are having to feel their own way through and find their own solutions.   This week, we discussed reusing medication, training, testing, and CQC’s Emergency Support Framework

Next week providers will be discussing financial support from Local Authorities.  Different LAs are offering differing levels of support.  What strategies have providers found most effective at accessing the funds? 

We will also be discussing planning to facilitate relatives’ visits.  Recent experience has shown that changes in the law and guidance about social distancing are changed very abruptly and without consultation.  This may affect guidance on visiting care homes.  Providers are also noticing how affected residents are by their increased isolation with many displaying low mood.  How can visits be arranged in a way that mitigates risk to residents, staff and visitors?  This is a crucially important topic and will no doubt prompt a thoughtful and informative discussion.  The Zooms take place on Wednesdays at 10.30am  Please email me if you’d like to join:


Reusing Medication

The Department of Health’s Standard Operating Procedure (‘the SOP’)  for reusing medicines in care homes is causing disquiet particularly in relation to end of life care medication.  Providers reported that a medicines training company is advising providers to treat reused medication as homely remedies.

I would caution providers against that.  CQC’s guidance on homely remedies suggests that providers should take advice from a healthcare professional, such as a GP or pharmacist on the use of such medication.

In contrast, paragraph 5 of the SOP states:


“Unless the product is being supplied under a PGD or a patient specific direction, a new prescription must be obtained prior to supply to the new patient.” 


The medicines training company is therefore wrong to suggest that end of life medication, or any medication that normally requires a prescription, may be treated as a homely remedy.  That advice implies that consulting a healthcare professional is sufficient, when in fact, a prescription is still required.


Furthermore, the usual requirements regarding controlled drugs remain firmly in place.  Obviously, those do not apply to homely remedies.


In short, I would only consider reusing medication as a last resort if there is a real supply issue.  I would in all cases ensure the medication is prescribed to the new patient before reusing it, and follow the permission and information provisions set out in the SOP.



The regulatory requirement, and the duty of care, to ensure that staff are properly trained remains in force.  Providers are finding new ways of delivering the training – but they introduce their own risks.

Microsoft teams is proving a useful resource.  It enables training sessions to be delivered remotely across multiple sites.  Some providers with cinemas are using them effectively to deliver such sessions.  However, some staff have raised the point that they should continue to socially distance as far as possible and spending two hours in a room to receive training is not necessary.

Given the nature of Microsoft Teams and similar products, training could potentially be delivered in people’s homes, mitigating that risk.  Teams’ sessions can also be recorded so can be delivered when needed, and when staff are available.

As to effectiveness of training, that is a question that arises in respect of all training at all times, but it is particularly important to consider it in respect of online and remote training, which CQC inspectors are often sceptical about, and which may be new to some providers and/or staff.

Points to consider include:

  • Testing knowledge at the end of training
  • Seeking detailed feedback on training, and acting on it
  • Observing practice is in line with training
  • Considering training needs in response to incidents, in particular identifying any trends in incidents that might identify training needs across staff and services
  • Reflecting on training, and training needs, during supervisions
  • Providing refresher training at appropriate intervals.

Providers may also wish to see the Skills for Care page on training during Covid.  Skills for Care have developed 3 programs of training during Covid:  a rapid induction program; refresher training (8 topics for staff who urgently need refresher training because training has expired or will expire soon) and volunteer training.     All are delivered digitally by a number of accredited training providers.  Of note, there are no limits to the number of staff who can receive the rapid induction training without charge.

The page includes the following from Kate Terroni (Chief Inspector of Adult Social Care):

“We welcome the new guidance from Skills for Care on training staff during the COVID-19 crisis. We recognise that at this time providers will be prioritising providing care to people and that this may mean that training will be delayed. However, providers should make every effort to ensure that staff are competent, confident and skilled in providing safe care to the people using their service.

We understand the pressures that providers are facing and the difficult choices it may require them to make. We want to support providers in whatever way we can during this crisis period. We are on your side: we are here to work with you, to listen to you, and to support you with the inevitable tough decisions you will face.”


Incidentally, Skills for Care’s Guidance from other agencies page is a useful and well updated list of current guidance.


Providers are questioning whether frequent testing is helpful if it is taking up to three weeks for results to come back.  Testing at three week intervals may therefore be appropriate.  However, some providers are finding it difficult to find couriers to collect the samples before they expire, and many samples are still coming back with inconclusive results.

Testing residents with dementia is particularly difficult and there was discussion around needing to balance the quality of life with any benefits of testing.  Some older residents with capacity have declined tests on the reasonable ground that if they are asymptomatic, a positive test is unlikely to benefit them.

This is an area we will no doubt return to in coming weeks.  It would be interesting to hear from providers who have successfully overcome some of these issues.


CQC’s Emergency Support Framework (‘ESF’)

CQC’s records of the ESF calls are not an accurate account of what was discussed.  Some CQC inspectors are recording the calls which providers welcome as it ensures there is an accurate record.  However, practice in this regard seems to vary.

Providers have experienced inspectors objecting to managers having other people in with them during the call such as regional managers.   I commented that I found that very disappointing.  The calls are not inspections, let alone exams or tests.  The practice is not consistent with Kate Terrroni’s comments above.  I am contacting CQC to seek clarity on these points and meanwhile suggest that providers push back on any such objections, and take an accurate note of calls which they share with CQC and other stakeholders after the call.

Healthcare Counsel’s Weekly Zooms take place on Wednesdays st 10.30.  Contact for details.


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