The transcript that follows this brief introduction is from a talk given by Nicola Lochery that we recorded on our last refresher about the RRN (Restraint Reduction Network) standards.
Nicola has done a lot of work mapping her training over to the RRN standards. She has also been looking at how some NHS trusts are only going to get a small percentage of their staff trained if they have to follow the Restraint Reduction Network standards. That will not only affect compliance issues, but will very possibly leave NHS staff vulnerable and the trusts open to challenges under Health & Safety legislation for failing to provide training to all those staff who need it.
The application process is very expensive and is likely to put smaller sized businesses out of business (which may possibly be an intentional discriminatory objective). It is impossible to become a centre with UKAS to offer an alternative to the BILD Certification scheme without having to pay them a 20% royalty rate.
All this to comply with a set of standards and certification scheme that are not mandatory because guidance has still not been issued by the Secretary of State for Health. Yet CQC are still (despite not being supposed to do so because it falls outside of their remit) telling certain agencies that they have to comply with these non-mandatory standards by April 2021.
The only reason the NHS and CQC are pushing for everyone to adopt these new standards and have BILD Act certification is because the NHS and/or Health Education England have made it a condition of contract that any training in a NHS hospital with a funded mental health unit must have them.
So you should be asking yourself “What do I get by adopting the RRN standards and BILD certification?” The answer seems to be nothing, apart of course from increased interference and more complicated logistical and bureaucratic processes.
The following is the transcript of Nicola’s talk.
“Now, I was going to talk to you about the RRN specifically, because obviously, it keeps raising its head. I don’t disagree with what the RRN is trying to achieve, in terms of I’ve spent the last eight years or nine years trying to get people to reduce the need for restraint in the environment. So they’re trying to get the restraints down, exclusion, seclusions. That’s what I’m trying to get them to do. And that’s basically the principles of the RRN. That’s the aim, the purpose of it.
The problem is that the way they want that to be done is probably not possible for most people, and the cost implication is horrendous. So what you need to do as trainers, when you’re being challenged about this is basically understand how your training fits those standards for a start, and address the managers.
I’ve got four acute trusts that I work with. Three of them have already re-signed up another contract with me for next year, regardless of what’s going on with this, because they’re happy with the training.
They’re also happy that they can answer the questions that CQC are going to ask them and you need to do the same with your clients.
What I did was I volunteered to do an hour’s training with their managers. I said, “I’ll do it, providing you get your operational managers into the room,” basically, because if you can get the operational managers into the room, then they’re the people that are going to have to answer those questions with CQC.
And if they don’t get the answers to those questions right, then the organisation is going to be in trouble and they’re going to have a big fail on the CQC inspection.
Then you need to approach it from two directions.
Firstly, make sure learning and development are in that meeting as well, because they’re the ones that are going to look at the issue from a logistical point of view and they will see that complying with these standards is not easy to do.
So what does the training consist of from the RRN’s point of view?
It’s a minimum of three day’s training. You’ve got one day that’s all on primary strategies. The second day is on secondary strategies and requires a minimum of three hours training, which all has to be face-to-face. Then you’ve got to cover the law and a certain element of review and restorative practices within the standards as well. So that’s basically your second day.
Then on top of that, you’ve got your restrictive practises or your breakaway techniques. So that’s going to be three days.
Therefore, you’ve got a minimum of three days just to meet the RRN standards.
One person phoned me up about a month ago and said, “Look, we’re really struggling. We do all our training in-house, and we’re getting pressure saying that we have to go along the route of the RRN. I know you’ve done some work around this, so can you come down and have a chat with us and show us how this works?”
So I went and met with this person and it transpires that he has two ways that he’s got to look at it. Firstly he’s got to approach it from how his training meets the standards. On review we identified that he didn’t meet some of the standards with his training.
He was doing conflict management and he was doing the physical breakaway and the law, but he didn’t have any preventative stuff in his system but he’s resolved that now. He’s doing some training himself, up-skilling, so that his trainers, him and another trainer are going to be able to do that preventative element. So they’ll add that into the curriculum.
Secondly he needs to track that. So basically, I’ve given him my tracking because he’s using my system.
I’ve put all the elements of my curriculum in that primary strategy which is phase one (what they call primary strategies) and then next to it, I’ve written which standards it meets. So 2.13, 2.14, whatever that looks like.
As a result, if somebody wants to see if my training meets the RRN standards they can simply go through it and find every single number in the standards alongside the training agenda. So that’s what you need to do with your training.
You need to figure out how you meet the standards. Then you can show them and educate the managers to say, “Look, when CQC is saying, ‘Are you registered with the RRN?” You can say, “This is how we meet those standards”, which actually might even be a better outcome, than the ones that are in the RRN. But you need to be able to show that, and the organisation needs to be able to answer those questions.
That’s the first thing you need to do, track your training against the standards, make sure you meet them.
The next thing you need to do is to show logistically, and this usually and unfortunately, has the biggest impact, how that works. So one person I know has got 17,000 staff at his acute trust. Now that’s about average. Some trusts have got 25,000 staff, another I know has got about 22,000 staff and one other have got about 10,000 so 17,000 is roughly in the middle.
If he was to put all his staff through three day’s training, which is the minimum standards by the RRN, using five training rooms and five trainers, this is the outcome. If every trainer worked seven days a week, 365 days a year, basically by the end of the year, with 18 people in a classroom, he would only get through 17% of his staff in the organisation through the training.
Now, bearing in mind that at the moment, you don’t get 18 people in a classroom because it would have to be a massive room. Also, the standards dictate that you can only have 12 people in your physical class, unless you’ve got two trainers and a bigger space anyway. And if we also consider the restrictions covid is placing on social distancing and how courses need to be run to be covid secure, that will possibly reduce numbers even further. So basically, he’s probably realistically only likely to get about 15% of the staff trained in a year.
For any of you that work in hospitals, you’ll also know that if you’ve got a course with about 18 people on, you’re lucky if you get 10 or 12 people turn up because they’ve had to go on shift. And if that goes up to three days training, where they’re off shift, that’s probably going to drop even less. So realistically, he’s probably going to look at 10% of his staff being trained by the end of that 12 months. That’s working every day of the year and having all the training rooms up and running.
And when you look at it again, the standards are prescriptive in that they say that you’ve got to do a one-day refresher every 12 months.
So on his next cycle, when he’s doing another 10% of his staff, he’s also got to somehow incorporate a one-day refresher and every four years, every single member of staff has to redo the full three days.
So logistically, by the time he’s up to his first cycle of doing it all again, he’s probably going to have only trained roughly 50% of his staff. That’s if they all stay and they don’t leave and he’s not got a high turnover of staff.
So again, it’s another way that you can approach the managers, bring it into that meeting or that training, whatever it is. Show them logistically how this will impact their trust and reduce their compliance figures. The learning and development departments heads will start spinning and fall off, to be honest, because they just go, “Well, we just can’t do it,” because it isn’t possible to do. And then you’ll get some people from compliance that will be saying, “But we have to do it because CQC are going to say that, so we have to meet that compliance,” when realistically they actually can’t do it if you just do the maths.
So it’s about educating them then in what meeting that compliance could look like, how your training meets that. If you’ve already got facts and figures to show data, that’s going to literally say, “Look, this is the impact that that training has had on other people,” then obviously, that’s better still. If you haven’t, you can use the figures I’m quoting here. But obviously, if you’ve got your own from that particular environment, that’s better.
And these standards are only applicable to “All providers of NHS-funded mental health, learning disability and autism services being required to use accredited training services” as it states on page 17 of the standards. So if CQC are pushing for other sectors to only use training providers that meet these standards, such as active hospitals and schools etc., they are acting outside of their remit because the standards do not apply to them.
It is actually a contractual obligation with Mental Health England. So if your provider or your organisation that you’re working in is not contracted by Mental Health England, then it doesn’t actually apply.
The problem is that CQC will probably use it as a way in which they can say, “Well, if they meet these standards, then we know that they’re doing the right thing,” which isn’t necessarily true. It just means that they’re ticking all the boxes that they’re supposed to be ticking.
The same thing arises when Ofsted come in and they talk about a single-person restraint.
Obviously, I don’t teach any single-person restraints, all the care environments that I’m working in are young people in my size or bigger, so nobody’s going to be able to restrain some of those children on their own without causing some kind of injury to themselves or someone else. It’s not realistic.
So again, address the manager, show them how you’re going to do that. If Ofsted are coming into an organisation and saying, “Well, what are you going to do if your young person runs into the middle of the road?” Well, I don’t have to answer that question if my risk assessment basically says, “My young person is not going to run into the middle of the road.” We don’t have to risk assess things that are not a risk. And if that person does, then we need to risk assess it.
But at the moment, it’s about educating your managers because they’re the ones that just panic. They panic when somebody comes in and asks them a question and they don’t know the answer. “Well, we don’t have a single-person hold.” Well, you don’t need it because your training says that firstly, we manage the behaviour so that the kid’s not going to run into the road. We understand the behaviour of the person, we have individual behaviour plans. We risk assess to say that, “This child is low risk of doing that,” or, “Is no risk.” And therefore, we don’t have to put something in place to manage a risk that doesn’t exist. And that’s all they need to be saying, but they don’t, they just panic. And certainly, probably about every 18 months, I’ll get an email through, off somebody, one of the care homes saying, “Can we not just put a single-person hold in?” to which my response is, “No, we just can’t put a single-person hold in and these are the reasons why”.
If they just turn round and say, “We don’t want your training because you’re not accredited to this,” or, “They don’t do this,” then address the managers. Show them how your training fits, how it’s better preferably, but certainly how they can answer those questions to CQC and Ofsted, because that’s what they need to know. That’s what they’re panicking about. They don’t really care whose training it is, providing it meets their needs and providing they can answer the questions that Ofsted or CQC are asking.
This is contractual with Mental Health England. So it’s the people that fund basically the care of people with mental health issues, learning disabilities or autism. And these standards are for people with restrictive elements in their training. So again, it wouldn’t affect any training that’s not restrictive, because of course, that’s the other avenue you can go down.
You can choose not teach restrictive practises but instead you can go in and teach preventative strategies or conflict management and not bother with the physical intervention element, and therefore, the RRN doesn’t come into play.
So whether they’d still have you deliver part of the training and someone else to deliver another part, I don’t know. Let’s watch this space and see.”
I personally can’t see this scheme going ahead. I have spoken to a lot of people all of whom think it will implode on itself and when you consider what has been stated above, you can see why.
The NHS is also under considerable financial strain as our many businesses due to this current pandemic, so it makes no sense whatsoever to burden them any further.
I don’t know anyone who likes it, but unless NHS trusts and business owners who will be affected by this start standing up and saying that they are not going to adopt it and/or an unbiased and impartial Government Minister looks into this properly, you will end up with it.
The choice is yours.
Other Related Blog Posts