{{org_field_logo}}
{{org_field_name}}
Registration Number: {{org_field_registration_no}}
Accessible Premises and Disability Inclusion Policy
1. Purpose
At {{org_field_name}}, we are committed to providing an accessible, safe, inclusive and non-discriminatory supported living service. We recognise that people may experience barriers because of disability, sensory impairment, communication needs, mobility needs, mental health needs, learning disability, autism, long-term health conditions or other individual circumstances. This policy explains how we identify and remove barriers, make reasonable adjustments, provide accessible information, support inclusive communication and promote equality, dignity, independence, choice and control.
This policy supports compliance with the Equality Act 2010, the Health and Social Care Act 2008, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, as amended, the CQC Fundamental Standards, the Accessible Information Standard, the Health and Care Act 2022, the Oliver McGowan Code of Practice on statutory learning disability and autism training, relevant fire safety requirements and building accessibility guidance where applicable.
In supported living, people usually live in their own homes or tenancies. {{org_field_name}} may not own, lease or manage the premises where a person lives. Where we do not control the premises, we will not assume landlord responsibilities. However, we will assess accessibility and safety risks that affect the delivery of care and support, support people to raise concerns, advocate for reasonable adjustments where appropriate, liaise with landlords, housing providers, commissioners and professionals, and record the actions taken.
This policy is intended to ensure that people can access care, support, information, involvement opportunities, complaints processes, activities and community life in a way that upholds their rights, dignity, independence and wellbeing.
2. Scope
This policy applies to all staff, agency workers, volunteers, contractors, people using the service, visitors and professionals who are involved with {{org_field_name}}.
The policy applies to provider-controlled premises, including offices, meeting rooms and any other premises owned, leased, managed or controlled by {{org_field_name}}. It also applies to care and support delivered in people’s own homes, tenancies and community settings where accessibility, communication, equipment, reasonable adjustments or environmental barriers may affect the safe and person-centred delivery of care.
This policy covers physical accessibility, reasonable adjustments, accessible communication, assistive technology, disability inclusion, emergency planning, staff training, workplace inclusion, confidentiality, complaints, governance and quality assurance.
Where a person’s home is owned, leased or managed by another party, staff must report any accessibility, safety or inclusion concerns to the Registered Manager. The person must be supported to raise the matter with the relevant landlord, housing provider, commissioner, social worker, occupational therapist or other appropriate professional, where this is needed and where the person consents or there is another lawful basis to act.
3. Related Policies
This policy should be read alongside the following policies:
- SL04 – Equality, Diversity and Human Rights Policy
- SL07 – Person-Centred Care Policy
- SL08 – Dignity and Respect Policy
- SL10 – Mental Capacity Act and Best Interests Policy
- SL11 – Consent to Care and Treatment Policy
- SL12 – Safe Care and Treatment Policy
- SL13 – Safeguarding Adults from Abuse and Improper Treatment Policy
- SL16 – Infection Prevention and Control Policy
- SL18 – Health and Safety Policy
- SL19 – Fire Safety Policy
- SL20 – Risk Assessment and Management Policy
- SL21 – Complaints, Concerns and Compliments Policy
- SL22 – Staff Training and Development Policy
- SL23 – Recruitment and Fit and Proper Persons Employed Policy
- SL30 – Governance and Quality Assurance Policy
- SL34 – Confidentiality and Data Protection Policy
- SL42 – Communication and Engagement with Service Users and Families Policy
Where local procedures are in place for housing, tenancy support, assistive technology, equipment, medication, lone working, emergency planning or fire safety, staff must also follow those procedures.
4. Accessibility of Premises, Homes and Support Environments
{{org_field_name}} will take reasonable and proportionate steps to ensure that any premises it owns, leases, manages or controls are accessible, safe and suitable for their intended purpose. Accessibility arrangements will be considered in line with the Equality Act 2010, CQC Regulation 15, relevant health and safety duties, fire safety requirements and building accessibility guidance where applicable.
Provider-controlled premises should be assessed to ensure that people can enter, move around and use the premises as safely and independently as possible. This may include considering step-free access, safe entrances and exits, suitable lighting, clear signage, accessible toilets where available, appropriate seating, safe flooring, handrails, ramps, accessible parking or drop-off arrangements, and suitable arrangements for people with sensory, mobility, communication or anxiety-related needs.
Where full physical access cannot be achieved immediately, the Registered Manager must ensure that alternative reasonable adjustments are considered and recorded. This may include offering meetings at an accessible location, arranging a home visit where appropriate, offering a remote meeting, providing information in another format, changing the time or location of a meeting, or agreeing another person-centred solution with the individual.
In supported living, staff must be alert to barriers in a person’s home or community environment that may affect the safe delivery of care and support. This may include unsafe access, unsuitable lighting, restricted space for equipment, trip hazards, inaccessible bathrooms, difficulties with entry systems, lack of suitable alarms, or communication barriers. Where {{org_field_name}} does not control the premises, staff must record the concern, discuss it with the person where appropriate, and escalate it to the Registered Manager so that the correct landlord, housing provider, commissioner, occupational therapist or other professional can be contacted.
5. Facilities, Adaptations and Equipment
Facilities, adaptations and equipment must be considered through individual assessment, environmental risk assessment, care planning and review. Where an adaptation relates to a person’s own home and {{org_field_name}} is not the landlord or housing provider, staff must support the person to request reasonable adjustments or adaptations from the appropriate party and must record any advice, referrals and actions taken.
Where needed, people may be supported to access adaptations such as grab rails, ramps, accessible toilets, adapted bathing facilities, non-slip flooring, height-adjustable furniture, specialist seating, communication aids, sensory adjustments or assistive technology. Staff must not arrange or use adaptations or equipment unless this is safe, appropriate and agreed through the correct process.
Equipment used to deliver care and support must be suitable for the person’s needs, safe, clean where relevant, maintained, stored appropriately and used correctly. Staff must only use equipment if they have received appropriate training and, where required, have been assessed as competent. Any faulty, unsafe or unsuitable equipment must be reported immediately and must not be used until it has been checked and confirmed safe.
Where technology or equipment may be restrictive, intrusive or involve monitoring, staff must consider consent, mental capacity, privacy, data protection, human rights and whether the arrangement is necessary, proportionate and the least restrictive option.
6. CQC Regulation 15: Premises and Equipment
{{org_field_name}} will ensure that premises and equipment used in connection with regulated activity are suitable, safe and properly maintained. CQC Regulation 15 expects premises and equipment used to deliver care and treatment to be suitable for their intended purpose, maintained, clean where relevant, securely stored and used properly.
The Registered Manager will ensure that provider-controlled premises are assessed for accessibility and suitability. Where risks are identified, an action plan must be put in place with clear timescales and responsibilities. The Registered Manager must also ensure that equipment used to deliver care and support is suitable for the person’s assessed needs and that staff understand how to use it safely.
Where a risk relates to premises that are not controlled by {{org_field_name}}, staff must record the concern, the person’s views, who has been contacted, any agreed actions, timescales and interim measures to reduce risk. This may include contacting a landlord, housing provider, commissioner, social worker, occupational therapist, community health professional, fire and rescue service or other relevant person.
7. Fire Safety, Emergency Evacuation and Personal Emergency Planning
Emergency procedures must take account of each person’s disability, mobility, sensory, communication, cognitive and mental health needs. People must be supported to understand emergency arrangements in a way that is accessible and meaningful to them.
Where {{org_field_name}} controls the premises, the Registered Manager must ensure that fire safety arrangements include suitable evacuation procedures for disabled people. Personal Emergency Evacuation Plans must be completed where a person or staff member may require assistance to evacuate safely from provider-controlled premises.
Where support is delivered in a person’s own home or tenancy, staff must consider whether the person needs support to understand, plan or practise what to do in an emergency. This must be reflected in the person’s care plan, risk assessment or emergency plan where relevant. Where the building is managed by a landlord, housing provider, managing agent or other responsible person, {{org_field_name}} will liaise with them where appropriate and lawful to support safe emergency planning.
Emergency planning must consider the person’s mobility, communication needs, sensory needs, understanding of risk, mental capacity, anxiety, distress, equipment needs, use of stairs or lifts, key access, staff support arrangements and emergency contacts. Any concerns about evacuation arrangements must be reported to the Registered Manager and escalated without delay.
8. Disability Inclusion in Service Delivery
{{org_field_name}} will ensure that disability inclusion is embedded in assessment, care planning, support delivery, reviews, communication, complaints, safeguarding, community access and involvement. Staff must recognise that disability inclusion is not limited to physical access. It also includes communication, choice, control, dignity, independence, relationships, culture, identity, privacy and equal access to opportunities.
People must be involved in decisions about their care and support. Staff must listen to the person’s views, respect their preferences and support them to make informed choices. Where a person may lack capacity to make a specific decision, staff must follow the Mental Capacity Act 2005 and the organisation’s Mental Capacity Act and Best Interests Policy.
Staff must support people to access activities, relationships, appointments, education, employment, volunteering, healthcare, leisure, cultural activities, faith activities and community opportunities where these form part of their assessed needs, wishes or outcomes.
9. Reasonable Adjustments
{{org_field_name}} will make reasonable adjustments so that disabled people are not placed at a substantial disadvantage when accessing care, support, communication, meetings, complaints processes, activities or involvement opportunities.
Reasonable adjustments may include changing the way a service or process is delivered, providing information in accessible formats, using interpreters or advocates, allowing more time for communication, changing appointment times or locations, adapting activities, supporting access to assistive technology, making environmental changes where premises are controlled by {{org_field_name}}, or liaising with landlords and professionals where changes are needed in a person’s home.
Reasonable adjustments must be discussed with the person and, where appropriate, their representative. They must be recorded in the person’s care and support plan, communicated to relevant staff on a need-to-know basis, and reviewed when the person’s needs change.
Staff must never refuse, delay or ignore a reasonable adjustment request without discussing it with the Registered Manager. Where a requested adjustment cannot be made, the reason must be explained clearly and alternative options must be considered and recorded.
10. Accessible Information and Communication
Staff must follow the Accessible Information Standard by ensuring that people’s information and communication needs are identified, recorded, flagged, shared, met and reviewed. CQC’s guidance confirms that adult social care services should follow this process for people with information or communication needs linked to disability, impairment or sensory loss.
At assessment and review, staff must ask each person whether they have any communication or information needs. This may include needs relating to hearing, vision, speech, learning disability, autism, dementia, acquired brain injury, mental health, literacy, language, digital exclusion or other communication barriers.
Communication needs must be recorded clearly in the person’s care plan, communication plan and relevant records. Important communication needs must be flagged so that staff can see and act on them. Where it is lawful and necessary, communication needs should be shared with other professionals or services so that the person receives consistent and accessible support.
Information must be provided in a way the person can understand. This may include Easy Read, large print, audio, braille, pictorial information, plain English, translated information, digital format, British Sign Language interpretation, Makaton, objects of reference, communication passports, speech-to-text, text-to-speech or other personalised communication methods.
Accessible communication must be used for assessments, care plans, consent, decision-making, complaints, safeguarding, medication information where relevant, emergency information, fire safety information, reviews and changes to service delivery.
11. Assistive Technology and Digital Support
Assistive technology and digital support may be used to promote independence, communication, safety, dignity and choice. It must not be used as a substitute for appropriate staffing, person-centred care or meaningful human contact.
Assistive technology may include speech-generating devices, hearing support, text-to-speech technology, reminder systems, adapted telephones, tablets, communication apps, environmental controls, falls sensors, call systems, smart lighting, door opening systems or other equipment that supports the person’s outcomes.
Before assistive technology is introduced, staff must consider the person’s wishes, consent, mental capacity, privacy, data protection, risks, benefits and whether the technology is necessary and proportionate. If the person may lack capacity to consent to the specific technology, staff must follow the Mental Capacity Act 2005 and best interests process.
The use of assistive technology must be recorded in the person’s care plan and reviewed regularly to ensure it remains effective, safe, appropriate and the least restrictive option.
12. Supported Living, Tenancy Rights and Community Inclusion
{{org_field_name}} recognises that supported living is based on people having their own home, tenancy rights, privacy, choice and control. Staff must respect the person’s home as their private living space and must not treat it as a care home or workplace controlled by the provider.
Staff must not make decisions about a person’s home, furniture, visitors, routines, adaptations, activities or lifestyle without involving the person and following the correct consent, mental capacity, safeguarding and tenancy processes.
Where a person needs adaptations or accessibility improvements in their home, staff must support the person to understand their options and, where appropriate, contact the landlord, housing provider, occupational therapist, social worker, commissioner, advocate, family member or representative. Consent must be obtained before sharing information unless there is another lawful basis for doing so.
Staff must record barriers to inclusion and the actions taken to reduce them. This includes barriers linked to transport, communication, digital access, finances, relationships, culture, religion, gender, sexuality, disability, mental health, community access or social isolation.
13. Staff Training, Competency and Awareness
All staff must receive training appropriate to their role so that they can provide inclusive, safe, person-centred and legally compliant support to disabled people.
Training must include equality, diversity and human rights, reasonable adjustments, the Accessible Information Standard, disability awareness, inclusive communication, safeguarding, dignity and respect, consent, the Mental Capacity Act 2005, safe use of equipment, fire safety, emergency planning, confidentiality, data protection, person-centred risk assessment and positive risk-taking.
Staff must also complete learning disability and autism training appropriate to their role. The Health and Care Act 2022 introduced a requirement for CQC-registered providers to ensure that staff receive role-appropriate learning disability and autism training, and the Oliver McGowan Code of Practice sets out standards for this training.
The Registered Manager must ensure that training is recorded, monitored and refreshed in line with the organisation’s training matrix. Where staff support people with specific communication, sensory, mobility, behavioural, cognitive or health needs, additional person-specific guidance, training or competency checks must be provided.
Staff must not use specialist equipment, moving and handling aids, communication systems or assistive technology unless they have received appropriate training and have been assessed as competent where required.
14. Workplace Inclusion for Staff with Disabilities
{{org_field_name}} will promote an inclusive workplace and will make reasonable adjustments for disabled applicants, employees, workers and volunteers in line with the Equality Act 2010.
Reasonable adjustments for staff may include accessible recruitment and interview arrangements, flexible working where reasonable and compatible with service needs, adjusted duties, adjusted hours, adapted workstations, assistive technology, accessible training materials, additional supervision, occupational health advice, Access to Work support or a phased return to work following sickness absence.
Information about a staff member’s disability or health condition must be treated confidentially. It must only be shared where there is a lawful basis and a need to know, such as implementing agreed adjustments or managing health and safety.
Adjustments must be reviewed regularly and whenever the staff member’s role, health, workplace or service needs change.
15. Confidentiality, Records and Data Protection
Information about a person’s disability, health, communication needs, reasonable adjustments, assistive technology, equipment or accessibility requirements is confidential personal information.
Such information must be recorded accurately, respectfully and securely. It must only be shared with authorised people who need the information to provide safe, effective and accessible care or support, or where there is another lawful basis for sharing. Records must be processed in line with UK GDPR, the Data Protection Act 2018, the Confidentiality and Data Protection Policy and relevant record-keeping requirements.
Staff may share accessibility and communication information with external professionals, emergency services, landlords, housing providers, commissioners or advocates where the person has consented, where sharing is necessary to provide care and support, or where sharing is necessary to protect the person or others from harm.
Records must clearly show the person’s identified needs, agreed reasonable adjustments, communication preferences, consent or mental capacity decisions, actions taken to address barriers, reviews and outcomes.
16. Accessible Complaints, Concerns and Feedback
People must be able to raise complaints, concerns, compliments and suggestions in a way that is accessible to them. Staff must support people to speak up and must not discourage, ignore or dismiss concerns about accessibility, discrimination, communication barriers or reasonable adjustments.
{{org_field_name}} will provide reasonable adjustments to support complaints and feedback. This may include Easy Read complaints information, large print, audio, pictorial or translated information, support from an advocate, representative or interpreter, extra time to explain concerns, meetings in accessible locations, communication aids or support to make a complaint verbally where written communication is difficult.
Complaints about accessibility, disability inclusion, communication or reasonable adjustments must be recorded, investigated and responded to in line with the Complaints Policy. The Registered Manager must review complaints and feedback for themes, patterns and learning, and must ensure that action is taken to improve accessibility and inclusion.
People must not be treated unfairly or disadvantaged because they have raised a complaint, requested a reasonable adjustment or challenged discrimination.
17. Monitoring, Governance and Quality Assurance
The Registered Manager will ensure that accessibility and disability inclusion are monitored through the provider’s governance and quality assurance systems. CQC’s current assessment framework continues to assess services under the five key questions of safe, effective, caring, responsive and well-led, supported by quality statements.
Monitoring will include accessibility audits of provider-controlled premises, review of reasonable adjustments, review of Accessible Information Standard compliance, review of care plans and communication plans, review of risk assessments, review of complaints and incidents, review of safeguarding concerns, review of staff training, review of equipment safety and feedback from people using the service, staff, families, advocates and professionals.
Where barriers or shortfalls are identified, the Registered Manager must ensure that an action plan is developed. The action plan must identify what needs to improve, who is responsible, the timescale for completion and how improvement will be evidenced.
Evidence gathered under this policy will support CQC assessment areas including safe care, effective support, caring practice, responsive communication and well-led governance.
18. Legal and Regulatory Framework
This policy must be read alongside the following legal and regulatory requirements:
- Health and Social Care Act 2008
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, as amended
- Care Quality Commission (Registration) Regulations 2009
- Equality Act 2010
- Human Rights Act 1998
- Mental Capacity Act 2005
- Care Act 2014
- Health and Care Act 2022
- Accessible Information Standard
- UK GDPR and Data Protection Act 2018
- Regulatory Reform (Fire Safety) Order 2005
- Building Regulations 2010 and Approved Document M, where applicable
- CQC Fundamental Standards
- CQC assessment framework
- Oliver McGowan Code of Practice on statutory learning disability and autism training
19. Responsibilities
The provider is responsible for ensuring that systems, resources, policies and governance arrangements support accessible, inclusive and non-discriminatory care.
The Registered Manager is responsible for implementing this policy, ensuring staff understand their responsibilities, monitoring compliance, ensuring reasonable adjustments are recorded and reviewed, ensuring Accessible Information Standard compliance, escalating unresolved accessibility or safety risks, and reporting findings through governance and quality assurance processes.
Staff are responsible for treating people with dignity, respect and fairness. Staff must identify and report accessibility barriers, follow communication plans and reasonable adjustments, record concerns and actions accurately, complete required training, and support people to raise concerns, complaints or requests for adjustments.
People using the service must be supported to express their accessibility and communication needs, make choices about their home and support, request reasonable adjustments, access information in a way they understand, and give feedback or complain in an accessible way.
20. Policy Review
This policy will be reviewed at least annually or sooner if required because of changes in legislation, statutory guidance, CQC requirements, CQC assessment methods, the Accessible Information Standard, fire safety requirements, building accessibility guidance, inspection findings, complaints, safeguarding concerns, incidents, audits, feedback or developments in assistive technology and best practice.
The Registered Manager is responsible for ensuring that this policy remains current, implemented and understood by staff. Any changes must be communicated to relevant staff and, where appropriate, to people using the service and their representatives.
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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