Doreen Wilkins

Olympic House
3 Olympic Way
Wembley, HAS ONP

T: 020 8795 6500
F: 020 8900 0277
W: www.candcheaithcare.co.uk

Christopher Morris
HM Area Coroner
Manchester South
1 Mottram St
Mount Tabor
Stockport

SK1 3PA

7 February 2018

Dear Mr Morris
Doreen Wilkins

You wrote to our Chief Executive, James Thorburn, on 16" November 2017
enclosing a Regulation 28 report arising from the inquest into the very sad death of a
user of our services, Doreen Wilkins. Our thoughts remain with Mrs Wilkins’s family
at this difficult time and we would like to thank you for affording us the opportunity to
take valuable learning from the incident for the benefit of those that use our services
now and in the future.

We are also grateful for your agreement to grant an extension to the deadline for our
response. Amongst my duties, | have oversight of health and safety, insurance and
range of legal matters and | have accordingly been asked to respond to your report
on behalf of Mr Thorburn. | have addressed the substantive matters below.

A clarification

Firstly, however, as a point of clarification, we would like to draw your attention to the
registration requirement identified in your report that Comfort Call was required to
submit monthly reports to the CQC showing “the actions that have been taken to
ensure staff rotas are meeting the needs of service users including time critical calls
and travel time between visits’.

The requirement above was extracted from Comfort Call’s certificate of registration
with the CQC. The way in which the certificate was formatted in its original version
was misleading in that it appeared to present the above requirement as relating to
Comfort Call as a whole, whereas it was in fact a requirement related specifically to
the Bristol office (now closed) alone.

Having realised this, we raised the matter with the CQC, who have since amended
the certificate such that it is now clear that the requirement was not in respect of

City & County Healthcare Group Ltd Registered Office: 2nd Floor, Olympic House, 3 Olympic Way Wembley HAD ONP. Registered in England and Wales, Registration Number 05456435.

Comfort Call as a whole (and therefore not of our office in Tameside to which the
inquest is related). A copy of the corrected certificate is attached for reference.

This is not to say, of course, that the duty of Comfort Call's Tameside office to
provide safe services (in accordance with reg.12 of the Health and Social Care Act
2008 (Regulated Activities) Regulations 2014) does not remain entirely pertinent and
we therefore address the matters of concern in the context of that duty rather than in
relation to any specific requirement of registration.

Matters of concern

Inadequate travel time is only one reason why a critical care visit might be late and it
is appropriate therefore that we explain the general policies and processes that are in
place to guard against critical care visits being missed (or late) to the extent that an
individual's safety is compromised.

When a referral is made to us by the local authority, any care needs will be identified.
These would include time-critical elements of the care, such as the need to provide
medication or food.

These critical needs will be included in the care plan loaded on to our roster system
and communicated to any care worker attending to the service user. It is therefore
clear to those coordinating as well as those delivering the services that the timeliness
of a particular call is of critical importance.

At present, if a care worker in the field were to find themselves running sufficiently
late for a critical care visit that the service user's safety might be put at risk (which
could happen for a variety of reasons), they would be expected to notify the local
office. The local management team would then take appropriate action, sending an
alternative care worker if necessary to ensure that the required care is delivered on
time.

To further reinforce the robustness of these policies and processes, we are also
introducing (during the coming weeks) new technology at the Tameside office that
will track care worker activity in real time. The Road Runner app is a mobile-based
technology which (amongst other things) allows care coordinators to flag critical care
visits. The system will then alert the coordinating team in the local office (or, outside
normal office hours, the out of hours coordinator) if a care worker fails to arrive for a
critical call. This in turn allows the coordinator to make alternative arrangements as
necessary in the manner already described above.

In summary, whilst a lack of rostered travel time would be a potential reason for a
critical care visit to be late, our systems are such that if a critical care visit were likely
not to be delivered on time (for whatever reason), alternative arrangements could
and would be made, mitigating the risk of harm. Furthermore, these failsafes are
about to become more robust through the introduction of new technology.

As well as the concerns around the delivery of critical care, your report also raised
the issue of inadequate travel time and the related issue of care workers leaving
assignments early to get to the next visit.

It would of course be a concern were any individual's care needs not met on any
particular occasion, but we would caution against assuming that the duration of call
commissioned in Tameside is necessarily precisely aligned with the amount of care
required in each instance. This is because care visits are commissioned by the
Council in blocks of fifteen minutes. Very few calls of just fifteen minutes are
commissioned, and where they are, these would tend to be for medication checks

City & County Healthcare Group ttd Registered Office: 2nd Floor, Clympic House. 3 Olympic Way, Wembley HA9 ONP. Registered in England and wales, Registration Number 6991398

only. Any call entailing personal care (washing, providing food etc.) would therefore
be likely to be commissioned for thirty minutes, even if the care tasks took, say, only
twenty minutes to complete. It should be clear from this, then, that in any given
instance, the fact that a call might have been curtailed by a few minutes is not
inherently inconsistent with the delivery of adequate care.

That said, this fact does not preclude the possibility that inadequate travel time in
care worker rotas could risk an individual not having as much contact time with the
care worker as they need. This fact had already been recognised by Tameside
Borough Council and | am very pleased to report that following discussions with
them, it has now been agreed that they will pay an additional sum for time spent
travelling between care assignments under their contract, thereby allowing us to
include travel time as a separate and discrete element in staff rotas, which we have
now done. This effectively increases the amount of time care workers will be able to
spend in direct contact with their service users, improving the quality of the service.

We trust that these new arrangements will satisfy your expectations in relation to the
prevention of future deaths, but if you do require further information, please do let me
know.

Yours sincerely

sth

Director of Policy and Communications

City & County Healthcare Croup td Registered Office: 2nd Floor, Olympic House. 3 Olympic way. Wembley HAS ONP, Registered in England and Wales, Registravon Number 6991398