CQC Report on a Smile Direct Club Shop
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- Published: Thursday, 07 April 2022 19:53
- Written by Peter Ingle
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Perhaps the UK’s best known direct to consumer orthodontic operation (DTC), is Smile Direct Club (SDC). Readers will probably be familiar with their advertisements on national television & social media. Despite their high profile, they may have taken a leisurely approach to meeting the requirements of the Health and Social Care Act 2008 including the requirement to register with the CQC.
Smile Direct Club’s UK operation would appear to be run through the company, Smiles Made Here Of UK Ltd. The CQC website now shows the company having seven sites in England, one of which is described as a mobile “SmileBus.” Six were first registered on March 30th 2021 and have not yet been inspected by the CQC. However the CQC have now managed to inspect the Aldgate branch in London. The inspection was carried out on the 19th of November 2021. It was published on March 28th 2022. By coincidence, a GDPUK contributor works at another practice whose report was also published on March 28th, the major difference being that it followed an inspection on March 8th
One possible explanation for the delay in publishing the SDC report may found in some of the conclusions reached, and perhaps a resulting period of interaction between CQC and SDC’s legal teams. Using the expressions that for years have struck terror into compliant practices, the final report concludes that the Aldgate branch was “Not well led” and “Required improvement.”
The inspection followed “information of concern we received and to check whether the registered provider was meeting the legal requirements in the Health and Social Care Act 2008 and associated regulations. The inspection was led by a Care Quality Commission (CQC) inspector who was supported by a CQC specialist dental advisor.” From their five possible Key Lines of Enquiry, CQC chose to restrict their inspection to the questions of safety and leadership.
The report starts by stating that, “at the time of completing this inspection report there was no registered manager in post as required as a condition of registration.” It continues, “The smile shop team consists nine smile guides who carry out the intra-oral scans. This team is supported by a district manager and a people and organisation manager. The shop has four scanning suites. A team of dentists who work remotely assess scans and other information provided to determine the suitability of the aligner treatment” From this it would seem possible that there may have been no GDC registrants on the premises at the time of inspection, apart that is from the CQC’s dental advisor. Indeed the report continues, “During the inspection we spoke with three smile guides, the district manager and the people and organisation manager.” Apparently contradicting itself the report continues, “Following the inspection, we spoke with the registered manager for the service at that time of the inspection.”
Specific concerns, were that, “The provider had staff recruitment procedures which reflected current legislation. However, records in relation to the checks carried out for dentists engaged in carrying out regulated activities were not available and not provided when requested.” In addition, “The provider had arrangements to monitor the competence, skills and experience of staff. However, records in relation to dentists engaged in carrying out regulated activities were not available and not provided when requested”
The CQC identified regulations the branch was not complying with. The report noted that they, “must establish effective systems and processes to ensure good governance in accordance with the fundamental standards of care.”
It then added a list of areas where the provider “could make improvements.” These included, taking a pre -treatment photograph in profile, discussing possible complications at the initial consultation, taking a scan or photograph when treatment was completed, reviewing staff awareness of Gillick competency, and reviewing the practice’s systems for analysing the results of audits and reviews.
Lastly there were the CQC Requirement notices. This is significant as the provider must send CQC a report that says what action they are going to take to meet these requirements. The Requirement notices mentioned in particular, information, “for the dentists who are engaged in the carrying out of regulated activities when we inspected. This included: Proof of identity, Satisfactory evidence of conduct in previous or other employment concerned with the provision of services relating to health or social care, or children or vulnerable adults. Information in relation to the competence, qualifications and skills were not available for the dentists who are engaged in the carrying out of regulated activities when we inspected.”
The full report can be read at: https://api.cqc.org.uk/public/v1/reports/3a177773-cc8f-4933-bb85-9f29ac10d748?20220328070227
How long will the CQC take before it inspects other SDC branches?
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