Article published in The Dentistry, October 2022
Alex O’Neill, head of compliance and customer success at Agilio Software, discusses the new National Standards of Healthcare Cleanliness.
When the new NHS Cleaning Standards were first published back in 2021, their existence caused a lot of confusion and spreading of misinformation in our profession.
Unlike the guidance from 2007, the new documents appeared to be lacking any dentistry-specific guidance and until this date, it is still not clear whether dental-specific templates will be provided by the NHS.
The head of compliance and customer success at Agilio Software, Alex O’Neill and his team recognised that more clarity was needed on the new standards for dentistry and made it their mission to use their years of compliance experience, expertise, and knowledge to help dental organisations meet the new standards.
From numerous emails with the team at the NHS to managing getting access to the Primary Care Templates, which are much more relevant to dentistry, Alex and his team went above and beyond to help make sense of the new standards.
We couldn’t think of anyone more suited to answer our questions about the National Cleanliness Standards before the 4 of November deadline when practices must be compliant with the new guidance.
1. Could you please explain how practices can best prepare for the looming 4 November deadline?
I think the initial step is to make yourself familiar with the new guidance and the available templates. The biggest difference from the 2007 guidelines, and I would also say the biggest challenge for meeting the new standards, is the lack of dental-specific guidance.
Unless you work with a compliance provider like iComply, you’ll need to work through a lot of literature, that might not be relevant to dentistry, and asses what applies to you and your practices.
You can do so by visiting the NHS website or if you are an Agilio iComply member you can benefit from our distilled dental-specific version that I and my team have created to make meeting the new standards as easy as possible. The shorter version alongside our customised templates is directly available on the Icomply platform.
Based on our ongoing communication with the NHS body responsible for the new guidelines, I have pulled together 10 key steps that practices will be expected to have in place by 4 November:
- Create a list of elements – if you are an Icomply member, you will have a dental-specific list of elements available on the platform
- Determine which Functional Risk (FR) categories apply to your practice
- Assign each room/area to a FR category
- Create a cleanliness framework and specification
- Create and display ‘Commitment to Cleanliness’ charter posters in each FR area
- Create FR-specific cleaning logs
- Agree on the technical audit process
- Update your policy and procedures and train your team
- Carry out technical audits for 50% of the practice
- Determine and display star ratings for each FR area and put improvement plans in place for any areas that score three stars or below.
2. Do the new National Cleanliness Standards apply to all dental practices across the country?
The simple answer is no, the new National Cleanliness Standards only apply to dental practices operating in England with at least one active NHS contract.
So, if you are a fully private dental organisation or you are based in Wales, Scotland, or Northern Ireland the new guidance will not affect you.
3. So, for private practices, would you recommend following the guidelines as ‘best practice’?
Considering the current climate in dentistry with its recruitment and rising cost challenges, I would say that adding another layer of compliance on top of the existing cleaning and decontamination regulations and guidance is unnecessary.
4. Could you help our readers determine which functional risk categories apply to dentistry?
The new guidelines include six Functional Risk categories ranging from one to six depending on the level of risk in an area. However, as I have mentioned previously, the guidance is very much put together with hospitals in mind. Therefore some of these FR categories won’t be relevant to dental practices.
From our understanding of the guidelines based on the GP templates and our communication with the NHS authority, we have determined that FR2, 4, 5 and 6 will apply to the majority of dental practices in England.
5. We’ve come across compliance management businesses claiming that only FR categories 2, 4 and 6 apply to dental. Why does Agilio recommend four rather than just three?
The subject of compliance by its very nature is open to interpretation, which can vary slightly depending on individual compliance providers.
At Agilio, we combine our many years of experience with our market-leading expertise to provide interpretations that we are confident will always keep dental businesses compliant.
6. According to the new standards how often do dental practices have to carry out audits?
There are three different types of audits named in the guidance: Technical, Efficacy, and External audit. The good news is that the external audit is not required for the NHS dental practices, and the Efficacy audit is only required annually.
In the case of technical audits, the frequency of carrying them is determined by what FR category the area falls into; FR2 is monthly, FR4 quarterly, FR5 six-monthly, and FR6 annually.
Specifically, however, to meet the 4 November deadline practices must audit at least 50% of the rooms in each FR area. This is due to the fact that practices must display star ratings that require a certain number of audits to be completed first in order to be calculated.
7. So, does this mean that every NHS contract holder in dentistry will have to audit 50% of their surgeries every single month?
Based on the new guidance, yes, practices will need to audit 50% of their surgeries every month as they fall into the FR2 category. If you are an Icomply member, the upcoming audits have automatically been added to your calendar from October ahead of the November deadline.
I, and the team, recognise the enormous pressure this can add to dental teams and resources.
That’s why we’ve worked exceptionally hard to make the documentation and processes within Icomply as clear and efficient as possible. It removes the headache of meeting the new standards.
8. As we understand the frequency of certain tasks in the new guidance is laid out as recommendations only, does it mean that it is not mandatory to meet those?
Yes, that is correct. However, unless you have robust evidence supporting your reasoning not to comply with the guidelines, I would strongly recommend following them, for now, whilst building the evidence to reduce frequencies when you perform an annual review.
9. What are your thoughts on the templates currently available on the NHS website, do you feel it is sufficient for dental practices?
The templates currently available in the public domain are designed for the hospital environment, making it challenging for dental practices to make sense of some of them.
In our conversation with the responsible NHS body, we have raised this and have been provided with primary care templates which are more relevant, but still not fully sufficient.
We have created our own templates that are only relevant to dentistry and managed to distil the original guidance from about 56 pages down to 11 of clear information about what practices need to do to meet the new standards.
I believe this is a great example of why having a compliance management partner like Agilio can save you so much valuable time and resources by enabling you and your team to focus on what matters to you.
10. Based on your experience, would you say that the current standards will be reviewed shortly by the NHS?
Yes, I think there is potential for some of the standards to be relaxed slightly. Working through the guidance, it became very clear to me that the standards are tailored to the hospital environment rather than dental surgeries.
I can see the NHS authorities addressing this issue in the future and hopefully revising the existing guidance to be better suited for dental practices.
11. It seems natural to ask what your motivation is considering all the trouble you and your team had to go through to source accurate information and customise the standards for dentistry in order to help the dental practices to meet the new standards.
As much as this might sound like a cliché, I really do care about the state of dentistry as an industry. I come from a family of clinicians, including my brother, which means I can see the struggles they endure on daily basis.
I recognise and have lived the pressures dental practices and their teams are under. So, I made it my mission to help to make dental practices a better place to work in.
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