New Long-Term Care Home Quality Inspection Program

Resident Quality Inspections (RQI)  
With the implementation of the LTCHA, all LTC Homes may be subject to an RQI inspection by LTC Home inspectors. An RQI inspection is a comprehensive inspection.  During a Comprehensive Inspection, if deficiencies are discovered, further issue specific inspections will be conducted. The following Inspection Protocols are used in all Home inspections:

• Admission processes
• Dining
• Infection prevention and control practices
• Resident charges
• Quality improvement practices
• Resident’s Council Interviews
• Family Council Interviews.

For all Homes, a standardized sample of residents (typically 40 in number) is randomly selected in advance from a provincial database.  The purpose of Stage 1 is to conduct preliminary reviews of the quality of care and quality of life indicators (QCLIs) of these 40 sampled residents using a structured set of questions.  This structured process ensures consistent results that are comparable across inspectors and Homes.

The RQI questions cover a wide range of QCLIs. Inspectors collect resident specific information in Stage 1 from observations, interviews (with residents, family, staff), and health records. The frequency of positive and negative responses to such questions as “Do you feel staff treat you with respect and dignity?” is analyzed by comparing them to thresholds shown through research to be predictive of the presence of non-compliance. Through analysis, this enables Inspectors to assess whether deficiencies may be present that warrant inspection in Stage 2.

The extent of an in-depth Stage 2 inspection is based on results of Stage 1 interviews, observations and record reviews. If there are no potential deficiencies from Stage 1, there is no need for the Stage 2 process. Stage 2 is the inspection of the triggered QCLIs from Stage 1.  This inspection is conducted by using the corresponding Inspection Protocol and by responding to the relevant questions within the Inspection Protocol(s).

These Inspection Protocols require LTC Home Inspectors to gather the information necessary to determine whether or not standards of care set out in the LTCHA, and its regulations, are in compliance.

Following are some examples of Inspection Protocols which may be triggered:

• Continence care and bowel management
• Dignity, choice and privacy
• Falls prevention
• Minimizing restraint
• Nutrition and hydration
• Pain management
• Personal support services
• Recreational and social activities
• Responsive behaviours
• Safe and secure home
• Skin and wound

All findings of non-compliance are documented within the inspection report. Inspectors have a duty under the LTCHA to identify in an Inspection Report all non-compliances found during the course of an inspection.

All inspections are unannounced (with very minor and narrow exceptions set out in s. 298 of Ontario Regulation 79/10 under the LTCHA) and the inspection schedule is randomized.

For each instance where ‘non-compliance’ with the legislation has been identified a decision must be made by the LTC Home inspector on the appropriate action to take, including whether to impose a sanction that is an Order.  At minimum the inspector will issue a Written Notification of Non-Compliance (LTCHA, 2007, C.8 s. 152.1).

Whether further action is required is based on an assessment of the following factors:

1. The severity of the non-compliance
2. The scope of the non-compliance
3. The licensee’s past history of compliance, in any Home, with requirements under the LTCHA and with requirements under the Nursing Homes Act, the Charitable Institutions Act or the Homes for the Aged and Rest Homes Act, the regulations under those Acts and any service agreement required by any of those Acts.  (O. Reg. 79/10 s. 299(1))

Inspectors are required to apply the definitions of severity, scope and history of compliance (see appendix A below) when deciding on other actions that may be taken which may include:

1. Voluntary Plan of Correction (VPC) – LTCHA, 2007, C. 8, s. 152.2
   • The inspector can make a written request for the licensee to prepare a written plan of correction for achieving compliance to be implemented voluntarily.  The licensee/Home is not required to submit the plan to the ministry.  There is no required compliance date set out in the inspection report.  The ministry expects to see compliance on the next unannounced inspection of the Home.
2. Compliance Order (CO) – LTCHA, 2007, C.8, s. 153 (1)(a) and (b)
   • The inspector may order a licensee to:
     1. do anything, or refrain from doing anything to achieve compliance with a requirement under this Act or;
     2. prepare, submit and implement a plan for achieving compliance with a requirement under this Act.
   • The licensee/Home is required to follow the Order to achieve compliance with the LTCHA within the timelines for compliance set out in the Order.
3. Work and Activity Orders (WAO) – LTCHA, 2007, C.8, s. 154 (1)(a) and (b)
   • The inspector may order a licensee:
     1. to allow employees of the ministry, or agents or contractors acting under the authority of the ministry, to perform any work or activity at the LTC Home  that is necessary, in the opinion of the person making the order, to achieve compliance with a requirement under this Act; and
     2. to pay the reasonable costs of the work or activity.
   • The licensee/Home is required to follow the Order to achieve compliance with the LTCHA within the timelines for compliance set out in the Order.
4. Written Notification and Referral to the Director (WN & Referral) – LTCHA, 2007, C.8, s. 152.4

   The inspector may issue a written notification to the licensee and refer the matter to the Director for further action by the Director

   Other Inspections
   The LQIP also includes other types of inspections, for example, where there are complaints or incident reports or there is a follow-up from a previous inspection. In this case Stage 1 of the RQI or Comprehensive Inspection is not applied. The relevant Inspection Protocols are used to delve directly into the issue and determine if the Home is compliant with the LTCHA and its regulations.

   Inspection Reports:
   There are two versions of the Inspection Reports and Orders issued by the MOHLTC – one is the licensee version (LTC Home operator) and the other a public version.  The public version usually follows after the licensee version, as it requires careful editing to remove as much of the personal health information (PHI) and personal information (PI) as possible.

   Licensee Report – The Licensee copy of the report is given to the licensee which contains all information related to the inspection including resident health information (confidential and not to be shared).

   Public Report - The Public copy contains all information related to the inspection with personal health information removed as much as possible.  This report is given to the Residents’ Council, and Family Council and posted in the Home.  Please note that the MOHLTC removes select information, such as identifying details, from the public version of inspection reports to ensure that LTC residents cannot be identified and in order to respect their right to privacy.

   Note:  Inspection reports are edited in an effort to strike a balance between the government’s commitment to information transparency and the need to protect and respect individual privacy, which involves taking all reasonable steps to respect the privacy of individuals by removing as much of their personal information (PI) and personal health information (PHI) as possible.

Levels of Severity of Non Compliance

Levels of Scope of Non Compliance

Levels of Compliance History