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Registration Number: {{org_field_registration_no}}

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Best Practice in Key Workers Policy

1. Purpose

The purpose of this policy is to set out how the Key Worker system operated by {{org_field_name}} will support person-centred, safe, consistent and compassionate care for people using the service.

The Key Worker system is an organisational arrangement adopted by {{org_field_name}} to support continuity, communication and coordination of care. Allocation of a Key Worker does not transfer the legal responsibilities of the registered provider, Registered Manager, registered professionals or any other member of staff, and does not authorise a Key Worker to make decisions on behalf of a person unless they are legally authorised to do so.

The Key Worker system will be operated in a manner consistent with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, as amended, including in particular:

• Regulation 9 – Person-centred care, by ensuring that care and support are appropriate, meet the person’s assessed needs and reflect their preferences;
• Regulation 10 – Dignity and respect, by protecting privacy, dignity, autonomy and independence and having due regard to relevant protected characteristics;
• Regulation 11 – Need for consent, by ensuring that care and treatment are provided with valid consent and, where a person lacks capacity to make a particular decision, that the requirements of the Mental Capacity Act 2005 are followed;
• Regulation 12 – Safe care and treatment, by supporting the identification, recording, communication and appropriate escalation of risks and changes in need;
• Regulation 13 – Safeguarding service users from abuse and improper treatment, by identifying and promptly reporting concerns about abuse, neglect, improper treatment or unlawful restrictions;
• Regulation 17 – Good governance, by supporting accurate, complete, secure and contemporaneous records and effective monitoring of care; and
• Regulation 18 – Staffing, by ensuring that staff undertaking Key Worker responsibilities receive the support, training, supervision and development necessary to perform those responsibilities competently.

This policy is intended to ensure that:

• Key Worker responsibilities are clearly defined and understood;
• people receive coordinated and person-centred support from a staff member who knows their needs, wishes and preferences;
• people are involved in decisions about their care and support to the greatest extent possible;
• consent, mental capacity and lawful decision-making requirements are respected;
• changes in health, wellbeing, risk or support needs are identified, recorded and escalated promptly;
• communication with relatives, representatives, advocates and professionals takes place lawfully and with appropriate regard to consent, confidentiality and information governance; and
• Key Workers receive appropriate training, supervision and management oversight.

2. Scope

This policy applies to:

• All Key Workers at {{org_field_name}}, ensuring they are trained and supported to fulfil their role effectively.
• People we support, ensuring that each individual has a named Key Worker who is responsible for their care coordination.
• Families, advocates, and other stakeholders, ensuring they know who to contact regarding an individual’s care.
• The management team, responsible for overseeing the Key Worker system and providing supervision.

3. Legal and Regulatory Compliance

The Key Worker system must be operated in accordance with all legislation and regulatory requirements applicable to the care and support being provided. Relevant requirements include:

Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, as amended

• Regulation 9 – Person-centred care: care and treatment must be appropriate, meet the person’s needs and reflect their preferences. Assessments, care planning and reviews must involve the person and, where appropriate and lawful, others acting on their behalf.
• Regulation 10 – Dignity and respect: people must be treated with dignity and respect. Their privacy, autonomy, independence and involvement in the community must be supported, with due regard to relevant protected characteristics.
• Regulation 11 – Need for consent: care and treatment must only be provided with the consent of the relevant person. Consent must be informed, voluntary and treated as an ongoing process. A person may refuse or withdraw consent at any time. Where a person aged 16 or over is unable to consent because they lack capacity to make the particular decision, staff must act in accordance with the Mental Capacity Act 2005.
• Regulation 12 – Safe care and treatment: risks to a person’s health and safety must be assessed and appropriate action taken to mitigate identified risks. Key Workers must promptly communicate and escalate changes in health, wellbeing, behaviour, risk or care needs in accordance with the person’s care plan and the service’s escalation procedures.
• Regulation 13 – Safeguarding service users from abuse and improper treatment: people must be protected from abuse, neglect and improper treatment. Key Workers must recognise and report suspected, disclosed or witnessed abuse, neglect, degrading treatment, inappropriate restraint, unlawful restriction or other safeguarding concerns without delay in accordance with the service’s safeguarding procedures.
• Regulation 17 – Good governance: the service must maintain effective systems and processes for monitoring quality, safety and risk. Records concerning each person must be accurate, complete, secure and contemporaneous and must include relevant care provided and decisions made about that care.
• Regulation 18 – Staffing: staff undertaking Key Worker responsibilities must receive the training, support, supervision, appraisal and professional development necessary to enable them to carry out those duties safely and competently.

Mental Capacity Act 2005

The five statutory principles of the Mental Capacity Act 2005 must be followed whenever there is a question about a person’s capacity to make a particular decision.

Staff must:

• presume that a person has capacity unless it is established otherwise;
• take all practicable steps to support the person to make their own decision before concluding that they cannot do so;
• recognise that a person must not be treated as lacking capacity merely because they make an unwise decision;
• ensure that any act or decision made on behalf of a person who lacks capacity is made in that person’s best interests; and
• consider whether the purpose of any proposed act or decision can be achieved in a way that is less restrictive of the person’s rights and freedom of action.

Mental capacity is decision-specific and time-specific. A Key Worker must not make a capacity determination or best-interests decision outside their competence or authority. Where there is doubt about capacity, this must be escalated to the appropriate senior member of staff and managed in accordance with the Mental Capacity Act 2005 and the service’s Mental Capacity and Consent Policy.

Any person claiming authority to make decisions on behalf of an individual, including an attorney or court-appointed deputy, must have their legal authority verified and the scope of that authority must be respected.

Equality Act 2010

The Key Worker system must be operated without unlawful discrimination, harassment or victimisation. Staff must have appropriate regard to a person’s relevant protected characteristics and must make reasonable adjustments for disabled people where required by law.

Care, communication and Key Worker arrangements must take account of the person’s individual needs, communication requirements, cultural identity, religion or belief, sexual orientation and other relevant characteristics and preferences.

Data Protection and Confidentiality

Personal information handled through the Key Worker system must be processed in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018, applicable confidentiality requirements and {{org_field_name}} information governance policies.

Information about a person must only be accessed, recorded, used or shared where there is an appropriate lawful basis and where the member of staff has a legitimate need to know. Information must not be routinely disclosed to relatives, friends or other third parties solely because of their relationship with the person.

Where the person has capacity, their wishes and consent concerning disclosure must be respected unless there is another lawful basis requiring or permitting disclosure. Where the person lacks capacity to make a relevant decision, information sharing must be considered in accordance with applicable law, including the Mental Capacity Act 2005, safeguarding requirements and the person’s best interests.

4. Managing the Key Worker System Efficiently

4.1. Role and Responsibilities of a Key Worker

A Key Worker is a named member of staff allocated to a person to support continuity, communication, person-centred care and coordination within the boundaries of the Key Worker’s role, training, competence and authority.

Allocation as a Key Worker does not give the staff member authority to make decisions on behalf of the person, undertake clinical assessments for which they are not qualified, authorise restrictive practices, conduct formal safeguarding investigations or carry out any task beyond their role and competence.

The Key Worker is responsible for:

• developing a professional, respectful and trusting relationship with the person while maintaining appropriate professional boundaries;
• knowing the person’s current care plan, risk assessments, communication needs, preferences, routines, strengths, goals, cultural needs and other information necessary to fulfil the Key Worker role;
• supporting the person to participate actively in decisions about their care, daily life, relationships, activities and goals;
• recognising the person’s right to make choices, including choices that others may regard as unwise, where the person has capacity to make the relevant decision;
• seeking and respecting consent in accordance with their role and escalating any concerns about consent or mental capacity;
• contributing to care-plan reviews and ensuring that relevant information, observations and the person’s views are communicated to staff responsible for assessing, approving or updating the care plan;
• promptly reporting and escalating changes in physical health, mental health, behaviour, emotional wellbeing, communication, mobility, nutrition, hydration, skin integrity or any other relevant change in need;
• promptly reporting and escalating any new, increased or unmanaged risk;
• recognising and immediately reporting safeguarding concerns, including suspected abuse, neglect, improper treatment, degrading treatment, financial abuse, inappropriate restraint or unlawful restriction;
• supporting the person’s emotional and social wellbeing and opportunities for meaningful activity, relationships and community involvement;
• communicating with relatives, representatives, advocates and external professionals where this is appropriate, authorised and consistent with the person’s wishes, consent, confidentiality and applicable law;
• maintaining accurate, complete, factual, secure and contemporaneous records of information relevant to the Key Worker role;
• ensuring significant information is communicated promptly to the appropriate member of the care team and is not retained solely within Key Worker notes or informal communications; and
• escalating any matter outside their competence, authority or role to the Registered Manager, senior member of staff, registered nurse or other appropriate professional.

The Registered Manager retains responsibility for ensuring that the Key Worker system operates safely and effectively and that individual staff members are only allocated responsibilities for which they are competent and appropriately supported.

4.2. Assigning Key Workers

Where {{org_field_name}} operates a Key Worker system, each person will be offered a named Key Worker as part of the service’s arrangements for continuity and coordination of care.

Key Worker allocation will be based on the person’s assessed needs and preferences and the competence, availability and suitability of the staff member. Consideration may include:

• the person’s wishes and preferences;
• communication and language needs;
• cultural, religious and identity-related needs;
• relevant protected characteristics;
• the person’s preferred approach to receiving support;
• compatibility, where this can be considered lawfully and without discrimination;
• the staff member’s knowledge, skills, training and competence in relation to the person’s needs; and
• the Key Worker’s workload and ability to fulfil the responsibilities of the role effectively.

The person must be involved in the allocation wherever practicable and must be given an appropriate opportunity to express any preference or concern regarding the proposed Key Worker.

Where the person has difficulty communicating, staff must provide appropriate support and reasonable adjustments to enable them to express their views. This may include accessible information, communication aids, interpretation or involvement of an advocate where appropriate.

Where a person lacks capacity to make a particular decision relating to Key Worker arrangements, staff must act in accordance with the Mental Capacity Act 2005. Relatives must not automatically be treated as having legal decision-making authority. Any attorney, deputy or other representative purporting to make a decision on the person’s behalf must have the relevant authority to do so.

The Registered Manager is responsible for overseeing allocations and ensuring that:

• Key Workers are competent for the responsibilities allocated to them;
• workloads are reasonable;
• conflicts of interest or inappropriate professional boundaries are addressed;
• allocations do not result in unlawful discrimination;
• people’s concerns about an allocation are considered and acted upon appropriately; and
• suitable arrangements are in place during the Key Worker’s absence.

4.3. Induction, Training, Competence and Support for Key Workers

A member of staff must not undertake Key Worker responsibilities unless {{org_field_name}} is satisfied that they have received appropriate induction, information, training and support and are competent to carry out the responsibilities allocated to them.

Training and development must be appropriate to the individual staff member’s role and the needs of the people they support.

Relevant training must include, as applicable to the staff member’s duties:

• person-centred care and care planning;
• dignity, privacy, equality and human rights;
• safeguarding adults and recognising and reporting abuse, neglect and improper treatment;
• the Mental Capacity Act 2005, consent and best-interests decision-making at a level appropriate to the member of staff’s role;
• recognising and escalating changes in health, wellbeing and risk;
• effective communication, including communication with people who have additional communication needs;
• confidentiality, information governance, the UK General Data Protection Regulation and Data Protection Act 2018 requirements relevant to the role;
• equality, diversity, inclusion and reasonable adjustments;
• professional boundaries;
• accurate, complete and contemporaneous record keeping;
• complaints and concerns, including how to escalate dissatisfaction expressed by a person or their representative; and
• any additional training necessary to meet the specific needs of people for whom the staff member acts as Key Worker.

Key Workers must receive appropriate supervision and appraisal and must have opportunities to discuss their Key Worker responsibilities, workload, competence, concerns and development needs.

Training and competence must be reviewed at appropriate intervals and whenever:

• the Key Worker’s responsibilities change;
• the needs of a person they support change significantly;
• a concern, incident, complaint or safeguarding matter identifies a learning need;
• legislation, statutory guidance or organisational procedures change; or
• supervision or performance monitoring identifies a need for further support.

Where a Key Worker is not competent or authorised to undertake a particular action, the matter must be referred to an appropriately trained or qualified member of staff or relevant professional.

4.4. Building Relationships and Supporting Emotional Well-being

• Key Workers must develop trusting and respectful relationships with the individuals they support.
• They should encourage open discussions about care preferences, ensuring individuals feel heard and valued.
• Emotional well-being support includes:
  • Encouraging participation in hobbies and social activities.
  • Providing comfort and reassurance during difficult times (e.g., illness, bereavement).
  • Advocating for the individual’s needs and wishes in care decisions.

4.5. Communication, Confidentiality and Coordination

Key Workers must support effective communication between the person, the care team and relevant professionals while maintaining confidentiality and respecting the person’s rights, wishes and choices.

Communication must be provided in a way the person can understand and must take account of their communication needs. Reasonable adjustments, accessible formats, communication aids, interpretation or other appropriate support must be provided where required.

Key Workers must maintain appropriate communication with:

• the person receiving care, ensuring that they are informed, listened to and involved in matters affecting them;
• members of the care team who require information to provide safe and effective care;
• relevant health and social care professionals where information sharing is necessary and lawful; and
• relatives, advocates, attorneys, deputies or other representatives where communication is appropriate, authorised and lawful.

Being a relative, friend or next of kin does not in itself give a person legal authority to receive confidential information or make decisions on behalf of an adult who has capacity.

Where the person has capacity to decide whether information should be shared, their wishes and consent must be respected unless another lawful basis requires or permits disclosure.

Where the person lacks capacity to make the relevant information-sharing decision, staff must act in accordance with the Mental Capacity Act 2005 and other applicable information-sharing and safeguarding requirements. Where an attorney or deputy is involved, staff must confirm that the individual has legal authority covering the decision in question.

Safeguarding information may be shared without consent where there is a lawful and necessary basis for doing so. Any uncertainty about disclosure must be escalated to the Registered Manager or other appropriate senior person.

Care records must be updated promptly following relevant Key Worker contacts, observations, discussions, decisions or actions. Records must be:

• accurate;
• factual;
• complete;
• legible;
• contemporaneous;
• appropriately attributed to the person making the entry;
• securely maintained; and
• accessible only to people with appropriate authority.

Records must include, where relevant:

• changes in needs, wishes or preferences;
• changes in health or wellbeing;
• identified or changed risks;
• relevant care-plan information;
• important conversations with the person;
• significant communications with representatives or professionals;
• consent, refusal or withdrawal of consent relevant to the Key Worker role;
• concerns about capacity that have been escalated;
• safeguarding or safety concerns and the action taken to escalate them; and
• agreed actions and follow-up required.

Urgent information about a person’s health, safety, safeguarding or wellbeing must be communicated immediately through the appropriate escalation process and must not be left solely for routine record review or the next Key Worker meeting.

4.6. Monitoring and Supervision of Key Workers

The Registered Manager must ensure that the operation of the Key Worker system is monitored as part of the service’s governance arrangements.

Key Workers must receive supervision at intervals determined by the service’s supervision arrangements and whenever additional supervision is required because of concerns, changes in responsibilities or changes in the needs of people they support.

Supervision must, where relevant, consider:

• whether the Key Worker understands and is fulfilling the responsibilities of the role;
• whether the Key Worker remains competent to undertake the duties allocated to them;
• the quality, accuracy and timeliness of Key Worker records;
• whether identified changes in need or risk have been appropriately recognised and escalated;
• whether people are being appropriately involved in decisions;
• consent and mental capacity issues relevant to the role;
• safeguarding concerns;
• professional boundaries;
• communication with relatives, representatives and professionals;
• workload and the Key Worker’s ability to fulfil the role effectively;
• training and development needs; and
• any concerns, complaints, incidents or feedback relating to the Key Worker arrangement.

The Registered Manager must ensure that appropriate quality assurance arrangements are used to monitor the effectiveness of the Key Worker system. This must include relevant review of care records and may include feedback from people using the service, representatives and staff.

Where monitoring identifies a shortfall, risk or failure to comply with the person’s care plan, this policy or applicable regulatory requirements, appropriate action must be taken promptly. This may include additional supervision, training, competency assessment, reallocation of the Key Worker role, changes to care arrangements or escalation through the service’s governance, safeguarding or disciplinary procedures.

Feedback from people using the service must be actively encouraged and must be taken into account when assessing whether the Key Worker arrangement remains suitable.

4.7. Review and Reallocation of Key Workers

The suitability of a Key Worker arrangement must be kept under review.

A Key Worker may be reallocated where:

• the person requests or expresses a preference for a change;
• the current arrangement is no longer meeting the person’s needs;
• the person’s needs change and require knowledge, skills or competence that the existing Key Worker does not have;
• there is a conflict of interest or concern about professional boundaries;
• the Key Worker is absent for a period that could affect continuity;
• the Key Worker leaves the service or changes role;
• the Registered Manager identifies concerns about competence, performance or suitability; or
• another legitimate operational or safeguarding reason makes reallocation necessary.

A request from a person to change their Key Worker must be considered respectfully and must not be dismissed without appropriate consideration. Where the request cannot be met, the reasons should be explained to the person in an accessible manner and recorded where appropriate.

Where reallocation takes place:

• the person must be informed and involved as far as reasonably practicable;
• the transition must be managed sensitively;
• relevant information required for continuity and safety must be handed over promptly and securely;
• information sharing must be limited to what is appropriate and lawful for the recipient’s role;
• outstanding actions, risks, appointments, care-plan matters and relevant concerns must be clearly communicated;
• records must be updated to identify the new Key Worker; and
• where practicable, a structured handover must take place between the outgoing and incoming Key Worker.

Where an immediate change is necessary and a formal handover cannot take place, the Registered Manager or delegated senior member of staff must ensure that the incoming Key Worker has access to the current care plan, risk information and other information necessary to provide safe and effective continuity.

5. Related Policies

This policy must be read in conjunction with the current versions of the following {{org_field_name}} policies and procedures, where applicable:

• CH07 – Person-Centred Care Policy;
• CH08 – Dignity and Respect Policy;
• CH13 – Safeguarding Adults from Abuse and Improper Treatment Policy;
• Mental Capacity and Consent Policy;
• Deprivation of Liberty Safeguards Policy;
• Confidentiality, Data Protection and Information Governance Policy;
• Care Planning and Risk Assessment Policy;
• Complaints and Concerns Policy;
• CH27 – Staff Supervision, Training and Development Policy; and
• any other policy governing the specific care, treatment, safeguarding or record-keeping responsibilities undertaken by the Key Worker.

Where there is any conflict between this policy and a statutory requirement, the statutory requirement takes precedence and the matter must be referred to the Registered Manager.

6. Policy Review

This policy will be reviewed at least annually and sooner where necessary following:

• a change in applicable legislation, regulations or statutory guidance;
• a material change in CQC regulatory guidance relevant to the policy;
• a safeguarding concern, serious incident or complaint that identifies a policy or practice issue;
• findings from audit, quality assurance, inspection or regulatory activity;
• changes to the service or to the responsibilities allocated to Key Workers; or
• feedback indicating that the policy is no longer effective or sufficiently clear.

The Registered Manager is responsible for ensuring that changes to this policy are communicated to relevant staff and that any resulting training, supervision or competency requirements are implemented.

Staff must work to the current approved version of this policy.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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