Under the Health and Social Care Act 2008, Holter analysis providers carrying out services in England are required by law to register with the CQC and submit themselves for inspection. Companies without CQC registration put themselves and their customers at risk, so why do we let those without registration/inspection play a part in our care pathways?
In 2019 we became the first wearable ECG monitoring company to be inspected by the CQC using the UK Government’s mandated rating system.
The NHS may have its issues but it is still regarded to be an aspirational healthcare model, by many countries globally, in terms of quality, service and value. Clinical governance is done particularly well in the UK with the benefit of independent regulatory oversight. We should be proud of Britain’s healthcare heritage and expertise.
It is a little known fact that some well recognised names in the Holter analysis market use third party overseas contractors in order to cut their costs (the market price for 24 hours of Holter analysis in South Asia is around the $5 USD mark). Clinical governance is very different in these countries with workers often reimbursed per report. We maintain that analysers should be paid for their time analysing reports rather than per report as the latter tends to have a negative impact on quality.
The CQC sets the standards expected of healthcare companies operating in England. Full CQC inspection is impossible if key aspects of the service are contracted offshore.
Holter analysis providers escape the oversight of the CQC in one of two main ways; firstly, by basing their Holter reporting staff offshore, they are able to attain CQC registration without exposing their clinical staff to CQC inspection. Secondly, they can avoid CQC registration altogether by claiming that their clinical governance is offshore.
“An activity is only a regulated activity if it is carried on in England. The meaning of ‘carried on’ is not defined in the legislation. But CQC takes it to mean to have ongoing direction and control of the activity.”
Joyce Frederick
CQC Deputy Chief Inspector
29 June 2020
To differentiate our services from other providers, ECG-On-Demand is a member of the Made in Britain organisation and is authorised to use their mark. All our physiologists are UK based and trained. They have all worked within the NHS and understand its idiosyncrasies.
The use of offshore contractors is not a theoretical risk. A side-by-side comparison, by a respected NHS tertiary care hospital, of ECG-On-Demand and a well known international company using offshore contractors, showed significant differences. The hospital uncovered a disagreement rate with the final report content of <0.5% vs >10%. Both providers are CQC registered and both have a good rating, however, the body of their CQC reports are substantially different!
At ECG-On-Demand we believe that all cardiac physiologists should be appropriately qualified and should be subject to effective clinical governance. We insist that all of our new cardiac physiologist recruits are registered with the Academy For Healthcare Science (AHCS), a joint initiative between UK health departments and professional bodies within the sector. The AHCS develops consistent regulation of cardiac physiologists and their allied health professionals as well as developing common standards for practice.
Our CQC report further solidifies our commitment to meeting and exceeding UK standards. The report found that our quality assurance was outstanding as we have a continuous and comprehensive quality improvement program achieved through continuous peer review and audit.
We believe that UK cardiology and its patients are best served by UK based Holter analysis providers who have undergone independent full CQC inspection.