Learning Disabilities Service – Restrictive Practice Reduction & Culture Reset
16-Bed Supported Living Service (Learning Disabilities & Autism) · East Midlands
The Crisis
A whistleblower referral. An unannounced inspection. Three residents under active safeguarding investigation. This service was not just facing enforcement — it was facing the end.
Restrictive practices — including physical restraint, mechanical restraint, and de facto seclusion — were being used without lawful authority, proper recording, or oversight.
CQC Rating: Inadequate (Safe, Caring, and Well-led). Requires Improvement (Responsive). Good (Effective)
Warning Notices were issued under Regulation 11 (Need for Consent), Regulation 12 (Safe Care and Treatment), and Regulation 17 (Good Governance). The local authority commenced a safeguarding enquiry under Section 42 of the Care Act 2014. Three individual residents were subject to active safeguarding investigations.
The provider faced an urgent timeline — to demonstrate compliance within 6 months or face cancellation of registration.
Our Intervention
Within 48 hours we were on site. The legal complexity here was significant — Mental Capacity Act, Liberty Protection Safeguards, Right Support Right Care Right Culture, and three active safeguarding investigations running simultaneously. Clinical and governance expertise had to work in parallel from day one.
Phase 1: Immediate Safeguarding & Legal Compliance (Weeks 1–4)
- Conducted a full restrictive practice audit across all 16 residents — identified 11 instances of unlawful restriction with no Mental Capacity Act assessment, Best Interests decision, or DoLS authorisation in place.
- Immediately suspended all informal restrictive practices pending lawful authorisation.
- Worked with the provider's legal team to submit urgent Deprivation of Liberty Safeguards applications to the supervisory body for 6 residents within 72 hours.
- Contacted the local authority safeguarding team to update on immediate actions taken — establishing transparency as a core strategy throughout.
- Reviewed all Positive Behaviour Support plans — only 4 of 16 residents had a current PBS plan; none referenced least restrictive options or de-escalation hierarchies.
- Introduced an emergency Restrictive Practice Register, recording every instance of restriction with date, duration, legal basis, and staff involved.
Phase 2: Culture Reset & Staff Retraining (Months 2–3)
- Delivered Right Support, Right Care, Right Culture training programme to all staff — 100% completion by the end of Month 2.
- Introduced PROACT-SCIPr-UK restraint reduction training delivered by an accredited external trainer, co-ordinated by Oxara Consulting.
- Replaced all existing behaviour protocols with individual, co-produced PBS plans developed with residents, families, and advocates where appropriate.
- Introduced a Restraint Reduction Action Plan with monthly targets — reduced use of physical intervention by 68% by the end of Month 3.
- Established a Restrictive Practice Oversight Group meeting fortnightly, chaired by Oxara Consulting — attended by the Registered Manager, clinical lead, and a family representative.
- Implemented a human rights-based approach framework across all care planning — each resident's plan explicitly referenced their Article 5 and Article 8 ECHR rights.
- Introduced accessible communication tools for non-verbal residents — including PECS, Makaton, and object-of-reference systems — to reduce frustration-triggered behaviours.
Phase 3: Governance Rebuild & Evidence Portfolio (Months 4–6)
- Rebuilt the entire governance framework to meet Regulation 17 — introduced a structured quality assurance cycle with documented evidence mapped to the CQC quality statements.
- Created a comprehensive Right Support, Right Care, Right Culture compliance evidence portfolio demonstrating adherence across all three pillars of the framework.
- Submitted Written Representations to CQC at Month 3 evidencing immediate actions against all three Warning Notices — CQC acknowledged receipt and agreed no further emergency action would be taken.
- Local authority safeguarding enquiry concluded at Month 4 — no further action required; provider commended for transparency and responsiveness.
- Achieved zero unlawful restrictions by Month 4 — all remaining restrictions lawfully authorised, reviewed, and recorded.
- Conducted a pre-inspection readiness review at Month 5 — all staff able to articulate PBS plans, legal frameworks, and individual communication profiles for their key residents.
Outcome
Month 3: CQC acknowledged Written Representations — Warning Notices under active review, no further enforcement escalation.
Month 4: Safeguarding enquiry closed — no findings against individual staff.
Month 4: Zero unlawful restrictions in place — all DoLS authorisations granted.
Month 5: Physical interventions reduced by 78% from baseline.
Month 6: CQC re-inspection — rating improved to Requires Improvement overall, with Good achieved in Safe and Caring.
Month 6: All three Warning Notices formally lifted.
Month 11: Full Good rating achieved across all five domains at follow-up inspection.
Clinical Lead Note
"Restrictive practice in learning disability services is rarely malicious — it is almost always the product of a culture that has never been given the right tools. The staff in this service were overwhelmed and undertrained. Once we gave them a lawful, person-centred framework and the confidence to use it, the restrictions fell away almost on their own. The culture reset was the intervention."
"The safeguarding enquiry felt like the end. The Oxara team didn't just help us survive it — they used it as the starting point for building something genuinely better. Every one of our residents now has a care plan that reflects who they actually are, not just what they need to be managed."
— Registered Provider, 16-bed supported living service, East Midlands