Miss Karen Bennetts

Profession: Occupational therapist

Registration Number: OT60373

Hearing Type: Final Hearing

Date and Time of hearing: 10:00 26/11/2018 End: 17:00 04/12/2018

Location: Health and Care Professions Council, 405 Kennington Road, London, SE11 4PT

Panel: Conduct and Competence Committee
Outcome: Suspended

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Allegation

Between April 2013 and  December 2016, whilst registered as an Occupational Therapist:

1. Your clinical reasoning and/or recording of your clinical reasoning for the recommendations made in respect of the following Service Users and/or the clinical reasoning was
inadequate:

a. Service User 1

b. Service User 3

c. Service User 12

d. Service User 13

e. Service User 15

f. Service User 22

g. Service User 27

2. In relation to Service User 2, you:

a. Did not provide Service User 2 with a copy of the final Therapy Review.

b. Assessed the suitability of a property without Service User 2 being present.

c. Did not promptly send a letter to Homechoice regarding the bathing assessment you conducted for Service User 2

d. Did not include the results of a bathing assessment in a letter to Homechoice, as was directed in supervision.

3. In relation to Service User 3, you:

a. Recorded contradictory statements within the assessment.

b. Did not make a case recording of the assessment visit carried out on 6 July 2015.

4. In relation to Service User 4, you:

a. Did not make a case recording of the home visit carried out on 31 July 2015.

b. Recorded an assessment which lacked sufficient detail and/or was contradictory in places

5. In relation to Service User 5, you:

a. Recommended equipment which was not suitable for and/or did not meet the needs of Service User 5.

b. Did not make a case recording of the assessment visit carried out on 9 July 2015.

c. Recorded an Did not record a detailed assessment which lacked
sufficient detail and/or was contradictory in places.

6. In relation to Service User 6, you recommended equipment that did not match the needs of Service User 6 and/or provided the service user
with an assessment document which was inadequate.

7. In relation to Service User 7, you:

a. Did not make a case recording of the assessment visit carried out on 15 July 2015 in a timely manner.

b. Recorded an assessment which lacked sufficient detail and/or was contradictory in places.

c. Recorded an assessment that lacked clinical analysis of Service User 7’s situation.

8. In relation to Service User 8, you did not make a case recording of the joint home visit carried out on 29 July 2015 and/or the further actions to be taken in the case.

9. In relation to Service User 9, you:

a. Did not consider adequately, or at all, the service user’s bathing needs.

b. Did not schedule a review of Service User 9.

c. Did not make a case recording of the assessment visit carried out on 15 June 2015.

d. Did not promptly submit the major adaption request

10. In relation to Service User 10, you did not undertake and/or record undertaking a review before closing the case.

11. In relation to Service User 11, you did not undertake and/or record undertaking a review.


12. In relation to Service User 11, you sent a housing letter instead of a housing support statement

13. In relation to Service User 13, you did not adequately record the bathing assessment.

14. In relation to Service User 15, you ordered equipment which was not suitable for Service User 15.

15. In relation to Service User 16, you did not submit the major adaptation paperwork in a timely manner.

16. In relation to Service User 17, you:

a. Acted outside the scope of your practice, in that you provided Service User 17 with dietary advice.

b. Did not record assessment within the therapy
assessment in relation to a straight stair-lift.

17. In relation to Service User 18, you did not record an adequate risk assessment within the therapy assessment.

18. In relation to Service User 19, you did not make and/or record making a referral for physiotherapy.

19. In relation to Service User 20, you did not submit the major adaptation paperwork in a timely manner.

20. In relation to Service User 23:

a. You did not make a case recording of the home visit carried out on 31 July 2015.

b. The assessment form you completed lacked suggested bathroom adaptation was not sufficiently clinical reasoning for the recommendations made detailed.

21. In relation to Service User 24, you:

a. Did not make a case recording of the assessment visit carried out on 30 July 2015 in a timely manner.

b. Did not capture and/or record adequate details of the property.

22. In relation to Service User 26, you:

a. Did not make a case recording of the disclosure of abuse by Service User 26 and/or the safeguarding alert raised in relation to the disclosure in a timely manner.

b. Did not submit the recommendation for a disabled facilities grant in a timely manner.

23. The assessment form you completed Iin relation to Service User 29 lacked sufficient detail and/or was contradictory in places you did
not record a detailed assessment.

24. The matters described at particulars 1 to 22 23 constitute misconduct and/or lack of competence.

25. By reason of your misconduct and/or lack of competence you fitness to practise is impaired.

Finding

Preliminary matters
Proof of Service
1. The Panel accepted the advice of the Legal Assessor. The Panel had sight of a letter dated 24 August 2018, sent to the Registrant at her registered address, giving notice of today’s hearing, and determined that service had been complied with in accordance with the Health and Care Professions Council (Conduct and Competence Panel) (Procedure) Rules 2003.
Proceeding in absence
2. The Panel heard and accepted the legal advice from the Legal Assessor, who referred it to the case of the GMC v Adeogba [2016] EWCA Civ 162, and the principles to be considered when deciding whether or not to proceed in the absence of the Registrant. The Panel had in mind the need to exercise its discretion to proceed with the utmost care and caution, particularly because the Registrant was not represented.
3. The Panel noted that on 31 July 2018 the Registrant was contacted by the HCPC with reference to a preliminary hearing in this case. In response the Registrant stated, in an email dated 31 July 2018, “I do not wish to attend any hearings as I do not have the funds for legal representation.” On 2 August 2018, the HCPC contacted the Registrant and provided her with the opportunity to attend by video link or telephone. The Registrant did not take up that offer. In relation to the Final hearing, the Registrant stated, in an email dated 3 October 2018, that she would not be attending for the same reasons as given before. She described the offer of telephone communication or a Skype link as “interesting”, but she did not want to take it up. She also reiterated that she would “definitely not be attending this hearing.”
4. Within the papers provided for the final hearing was a letter from the Registrant to Kingsley Napley solicitors who present the case on behalf of the HCPC. In that letter the Registrant stated, “I wish to state that the reasons I am not attending the hearing is that I do not have enough financial manes to afford a solicitor, to accompany me to the hearing and to present my case.”
5. The Panel was satisfied that the Registrant was aware of today’s hearing and that the hearing could go ahead in her absence in the event that she did not attend. In light of her correspondence, the Panel decided that the Registrant had voluntarily waived her right to be present at this hearing. The Panel noted that the Registrant faced serious allegations and there was a clear public interest in the matter being dealt with expeditiously. The Panel considered an adjournment would serve no useful purpose, because it seemed most unlikely that the Registrant would attend on another occasion, given her stated position. Furthermore, the Panel noted she had not requested an adjournment. The Panel took into account that there were three witnesses attending today, and three more due to attend, and was concerned about the effects of delay on their memories if the matter were to be adjourned.
6. The Panel concluded that it was in the interests of justice that the matter should proceed, notwithstanding the absence of the Registrant. The Panel would draw no adverse inferences from the Registrant’s non-attendance. Furthermore, the Panel had the benefit of detailed written submissions from the Registrant which it had read carefully and would take into account when hearing from the witnesses and in due course, when making its decisions on the facts.

Background
7. The Registrant is, and was at all material times, registered as an Occupational Therapist with the HCPC.
8. The Registrant was employed by Cornwall Council (the Council) as a Band 5 Occupational Therapist from April 2013 until December 2016. Concerns around the quality of the Registrant’s work initially arose during her probation period. Towards the end of that Probation period, 6 months after the Registrant had joined the Council, those concerns remained. During her second probation Review, on 24 October 2013, the Registrant disclosed she was dyslexic. This disclosure was not volunteered but rather prompted by a manager, who had asked the Registrant whether she had any learning difficulty which might account for some of the difficulties demonstrated in respect of her recording. Upon learning of the Registrant’s dyslexia, the manager directed the Registrant to contact ‘Access to Work’ (ATW) for the purposes of a referral. The manager also arranged for one to one supervision to continue on a fortnightly basis and for the Registrant’s probation period to be extended for a further 3 month period.
9. The ATW assessment took place on 3 December 2013 and special equipment and training in the form of ‘ClaroRead Plus and Inspiration computer software, a noise-cancelling headset, a Digital Voice Recorder (DVR), DVR Training and Assistive Software Training’ was approved on 6 December 2013. These reasonable adjustments were then put in place to support and assist the Registrant in her practice. In addition, the Registrant was assisted by overlays, coloured papers, different fonts, quiet working spaces, the option to work from home on occasion and, in the latter period of her employment, dedicated administrative support. She was also provided with extensive supervision for nearly three years.
10. The Registrant successfully passed her probation period on 15 January 2014. However, on 18 March 2015, a complaint was received from a service user (unconnected to these proceedings) about the quality of an assessment conducted by the Registrant. As a consequence of that complaint, the Registrant’s caseload was audited. The audit identified further areas of concern and an Improvement Plan was put in place effective from 13 April 2015, for a period of eight weeks.
11. On review of the improvement plan on 10 June 2015, there remained on-going concerns about the Registrant’s capability and standards of practice. The formal capability procedures were invoked, effective from 30 June 2015. In order to support the Registrant through this process she was allocated a new supervisor who would hold weekly supervisions with her, in addition to checking all her assessments and providing feedback.
12. Notwithstanding the additional support, by 27 January 2016, the Service Manager in Adult Social Services at the Council remained concerned that the Registrant’s ‘assessment of cases contained too many errors and omissions & lacked clinical reasoning’. For that reason a Stage 2 Capability warning was issued. In order to support the Registrant through this process she was assigned a mentor/clinical supervisor who was to assist the Registrant with all assessments for a 3 month period.
13. By April 2016 the mentor/clinical supervisor was of the view that “it would not be feasible to allow Karen to work without a high degree of supervision, much more than would normally be the case for a Band 5 OT with three years experience within this service (i.e. one session every six weeks would be the norm). In my opinion our service does not have the capacity to be able to continue to offer this intensive supervision.”
14. A capability review was held on 17 May 2016, in which it was decided to replace the mentor/clinical supervisor with a different supervisor. The Service Manager commented: “Following this 3 month period of intensive support, I propose that you now be allowed to work more independently and that I review your cases over the next 3 months. If there is not a significant enough improvement, I may need to convene a stage 3 hearing…’”
15. On 3 October 2016, Stage 3 Capability proceedings were initiated. The areas of on-going concern were identified as “a lack of clarity of clinical reasoning, omissions in service users assessments, poor recording in assessments including unprofessional language & statements that do not make sense, failure to follow supervisors instructions.” The Registrant left the Council’s employment in December 2016.

Witnesses
16. The Panel heard from six witnesses called on behalf of the HCPC:
• VI - Approved Mental Health Professional, Best Interest Assessor and Occupational Therapist and the Registrant’s previous line manager
• PB - Band 5 Occupational Therapist at Cornwall Council and the Registrant’s previous line manager
• RG - Community Independence Team West Manager at Cornwall Council and the Registrant’s previous line manager
• AW - Service Manager at Cornwall Council and the Registrant’s previous line manager
• KI - Service manager at Cornwall Council and the Registrant’s previous line manager
• AE - Dyslexia Specialist
17. The Registrant did not attend. As mentioned above, she had provided detailed written submissions that were contained within the main bundle, together with a separate bundle with a letter dated 16 October 2018, and the Panel took all this material into account when considering the evidence of the witnesses and also when making its decisions in this case.
Decision on Facts
18. In reaching its decisions on the facts the Panel took into account the evidence provided by the witnesses called by the HCPC and all the documentary evidence, together with the submissions made by Ms Sheridan. The Panel also took into account the detailed written submissions made by the Registrant and the documents she had provided with those submissions. The Panel accepted the advice of the Legal Assessor and bore in mind that it was for the HCPC to prove its case on the balance of probabilities. It was not for the Registrant to disprove the allegations.
19. The Panel found VI to be a credible and reliable witness who was fair and balanced, referring to the Registrant’s many positive characteristics.  She respected the Registrant’s abilities and did her best to assist the Panel. Her oral testimony was entirely consistent with her witness statement. VI’s evidence was largely based on clinical records, which the Panel had the benefit of seeing, and also her supervision sessions with the Registrant during the time that she was her Line Manager.
20. The Panel found PB to be a credible, objective and helpful witness. He was able to speak of his first-hand knowledge of the Registrant during the time that he was her Line Manager. He spoke of their supervision meetings and the additional support put in place to assist the Registrant. He also gave evidence about the Registrant’s caseload, which he knew well, and the work they did together to reduce it and make it more manageable. He was able to speak about specific cases where, from the records kept by the Registrant, he found there to be areas of concern. The Panel considered him to be balanced and fair and he spoke positively about the Registrant in particular areas. He recognised that the intense supervision could be perceived as punitive by the Registrant and he was empathetic, but he was “more concerned with putting things right.” He was surprised at the Registrant’s negative comments about their working relationship and he listed all the support that he tried to provide to assist her.
21. The Panel found RG to be a credible and consistent witness. He was brought in from another team and asked to line manage the Registrant for a period of approximately four months in 2015. He was able to speak about the nature of the supervision required, which he said was far in excess of that expected of someone who had been employed in her role for two and a half years. During his time supervising the Registrant he said he was not confident that she was able to act in the autonomous role of an Occupational Therapist and said that his concern was that the Registrant was not clinically reasoning things through. He told the Panel how he was having to see the Registrant for supervision sessions every week for two hours at a time and sometimes twice a week because there was so much to get through. This was in contrast to the usual position with someone of the Registrant’s level of experience, which would be once a month for about an hour. The Panel considered RG to be a fair witness who spoke favourably of the Registrant in some respects.
22. The Panel found AW to be a credible and helpful witness. She was careful to say when she did not have knowledge of matters which were put to her and clear and helpful with the chronology of the case and the professional development of the Registrant. Her evidence was consistent with that of other witnesses. She was the first person to supervise the Registrant and did so from the time when the Registrant was initially employed at the Council in April 2013 until the end of her probation in January 2014 and then later from February to April 2016. She dealt with the concerns the Council had with the Registrant during her probationary period and the Registrant’s disclosure that she had dyslexia.  She said at the time they thought that may have been the key to some of the difficulties the Registrant appeared to be experiencing. Following that disclosure ATW made various recommendations (as detailed in paragraph 9 above), all of which the Council implemented, she said.  She was very fair, empathetic towards the Registrant and considerate in her answers.
23. AW said that the Council identified two areas where the Registrant was experiencing difficulty, namely recording and processing and also with organising her work and thoughts, and thus her clinal reasoning, and coming to conclusions to decide what options to pursue for people. AW supervised the Registrant on a second occasion in 2016. This was after reasonable adjustments had been made in light of the Registrant’s disclosure about her dyslexia and she had been provided with the support and assistance referred to above. AW said she was surprised that the Registrant was still making the same kind of mistakes she had been making earlier about which, she said, “you would not expect with someone after three years.” This was particularly in relation to her clinical justifications. AW said that during that three month period she had been having supervision sessions with the Registrant almost every week for about two hours at a time. This was in contrast to the normal position of someone qualified for three years, which would be to see them once every six weeks for about an hour. Although AW felt that the Registrant was “really trying and making an effort”, there were still errors occurring. In AW’s view in 2016 the Registrant was requiring supervision of a level that was “not really sustainable.”
24. The Panel found KI to be a credible and forthright witness. She was thorough in her answers and clearly doing her best to assist the Panel. KI supervised the Registrant’s various line managers from September 2013 onwards, but did not work with the Registrant directly. She provided detail about the Registrant’s probation period, its extension because of concerns raised, action plans that were put in place to assist the Registrant and advice sought from Human Resources following the Registrant’s disclosure that she was dyslexic. The Registrant was then assessed by the Department of Work and Pensions (DWP), through the British Dyslexia Association, and the DWP confirmed it would provide funds towards the cost of certain provisions to assist the Registrant in her work. The Council also contributed towards the cost of the equipment and training, detailed in the background above. KI agreed that she was aware that, in addition, the Registrant was provided with dedicated administrative support in the latter part of her employment. KI also provided detail about neuro diversity training provided to help staff understand and work with those who were dyslexic. She said that at the time there were ten dyslexic members of staff, so this was not just directed at assisting with the Registrant.
25. KI said that a ‘Coaching Report’ was provided for the Registrant by ‘Genius Within’, which comprised four sessions, concluding on 28 July 2014. The report identified key areas of the Registrant’s work including, for example, memory, organisation, time management and stress management. It identified problem areas and strategies to cope with them.
26. KI said she could sympathise with the Registrant’s feeling that she was being over scrutinised and that this impacted upon her performance. However, she said that as a "responsible manager”, she had a duty to put the protection of service users first and also to ensure that the Council’s resources were not wasted.
27. Following the concerns raised about the Registrant’s practice, KI carried out a review of her cases and noted a general trend of concerns. She also provided evidence about the subsequent capability process which culminated in the Registrant’s dismissal. KI was candid in saying that although she tried to manage the Registrant in a straightforward way, she recognised that, as “the boss of the Registrant’s bosses”, the Registrant could have been “a bit scared of me.” She refuted any suggestion that she treated the Registrant unfairly or was in any way trying to have her removed from the Council. She said she was not aware of any bullying, harassment or discrimination directed at the Registrant.
28. AE was an expert witness and provided the Panel with straightforward, helpful evidence about dyslexia. She had carried out an assessment of the Registrant and responded appropriately to the criticisms made of her by the Registrant. She said that people with dyslexia, with the appropriate support and software and professional training, would be expected to achieve as competently as their peers, or indeed more so because “they are so diligent in their wish to achieve in order to overcome their difficulties.’’ She was thus surprised that the Registrant’s difficulties continued after the support and intervention provided, but considered that the concerns could in part be attributed to dyslexia. She said that the equipment said to have been provided to the Registrant should have assisted the Registrant, as long as she was trained in how to use it and had specialist support to develop strategies from a specific tutor such as those supplied by ‘Genius Within.’ AE accepted that there was a spectrum of dyslexia and said that she would place the Registrant as medium to mild on that spectrum.
29. There was a common theme with the various line managers in that they said that they would provide the Registrant with direction in relation to an identified difficulty, such as clinical reasoning or recording. However, although her assessments often showed initial improvement, she was unable to sustain this progress.
30. In light of the evidence provided, the Panel was satisfied that the reasonable adjustments put in place to support and assist the Registrant were appropriate and that, in line with the evidence of the expert, the Registrant would be expected to achieve as competently as her peers. It appeared, however, that the Registrant may not have fully availed herself of the support provided. In so far as the Panel found facts proved, it did not consider the Registrant’s dyslexia to have contributed in any significant way to the failures identified, although it could not rule out the possibility that it had in some part contributed.
31. The Panel took into account the Registrant’s written representations that she was given no support, but this was in direct contrast to the compelling evidence given by all the line managers who had supervised her. It was clear the Registrant felt she was being over scrutinised and many of the witnesses could see why she might feel that way because she was being very closely monitored. The recurring theme, however, was that they had done more for the Registrant than any other member of staff and had “bent over backwards” to help her. It was clear to the Panel that the Registrant was most upset with the way in which she felt she had been treated, but the Panel was not persuaded that she lacked support or that KI was in some way conducting a campaign to get her removed. KI said that the Registrant had seven supervisors in total and they all told her the same thing about the Registrant’s performance issues.
32. Notwithstanding the Registrant’s assertions in her written representations that she was bullied, harassed and discriminated against, the Panel heard no evidence to support such assertions.


Particular 1
1. Your clinical reasoning and/or recording of your clinical reasoning for the recommendations made in respect of the following Service Users was inadequate:

a. Service User 1
b. Service User 3
c. Service User 12
d. Service User 13
e. Service User 15
f. Service User 22
g. Service User 27

a. Service User 1 - proved

33. In relation to Service User 1 the Panel heard from RG, who was supervising the Registrant at the relevant time. He provided detail about Service User 1, a man in his early sixties suffering from depression, epilepsy, oedema and bilateral hand tremors. He said the Registrant carried out a home visit on 8 September 2016. The purpose of that visit was for a bathing assessment and also an access assessment. The Registrant recommended a ramp up to the front door and said the reason for this was because the service user’s wife was asking for that modification. RG said that the Registrant should have provided clinical reasoning for her recommendation and that it was not sufficient reasoning to say that a service user or family member had a preference for an adaptation. He added that it was not that the Registrant came to the wrong recommendation necessarily, but that she had to provide the necessary clinical justification in the assessment.
34. In her written representations, the Registrant identified why it was that she recommended a ramp and said, “The assessment of Su1 is clearly identified.” She said she included the wife’s views because, “I place high value on family members who support their spouses cope with disability.”
35. The Panel had sight of the assessment completed by the Registrant and accepted the evidence of RG that it lacked clinical reasoning in the nature described by RG and so it was inadequate. Having found the clinical reasoning inadequate it followed that the recording was also inadequate.  The Panel therefore found Particular 1(a) proved.
b. Service User 3 - not proved
36. In relation to Service User 3, PB gave evidence and provided detail about the service user and the bathing assessment carried out by the Registrant on 6 July 2015. He said that in the assessment the Registrant did not correctly adopt the ‘ladder approach’. He described this as a step-by-step approach to meeting the needs of the service user with the minimum intervention of equipment or adaptation necessary. PB said that the Registrant recommended a level access shower without properly assessing if other, less costly and intrusive, solutions could have been found. He expected the Registrant to have recorded that she had trialled a bath board, swivel bather or bath lift to see if any of these allowed Service User 3 adequate access to washing facilities to meet her personal hygiene needs.
37. In her written representations, the Registrant said that PB was not present at the assessment and therefore it was impossible for him to replicate what she had seen on the visit. She said she had observed the client struggle to transfer her legs over the edge of the bath. She said the screen of the bath did not make it possible to trial a bath board because it did not swing back. She said that even if the screen were removed the client would have struggled to undertake the transfer. She therefore deemed it both practical and safe to provide a level access shower.
38. The Panel was of the view that the Registrant’s approach appeared to be focused on resolving the long term needs of Service User 3, who had a degenerative neurological condition. The Panel was satisfied that this was a professional judgement on the part of the Registrant and that her reasoning, as recorded, was adequate. The Registrant identified the risks associated with the service user’s daily bathing care and the involvement of the spouse. The Panel was not persuaded that the reasoning and recording of the reasoning were inadequate and therefore found Particular 1(b) not proved.
c. Service User 12 - not proved
39. PB told the Panel that he detailed a number of deficiencies in a Therapy Overview Assessment dated 15 June 2015, for Service User 12 that had been completed by the Registrant. His evidence was that: there could have been more information about the property itself; there was no discussion of the service user's eligibility for a level access shower; there was no description of the bath and whether it had an over-bath shower; there was no  exploration of why the service user was sleeping downstairs; there was an inadequate description of the service user as ‘frail’ under mobility; there was nothing about toilet transfers; and there was no discussion recorded of means eligibility.
40. The Panel noted that PB had not dealt with Service User 12 in his statement and that the Registrant had not referred to this service user in her written representations when referring to the evidence of PB. However, after receiving legal advice from the Legal Assessor, the Panel had allowed this allegation to be explored with PB since he was the person who had been directly involved. His evidence on the issue was clearly relevant and the Panel noted that, although the Registrant had not commented on Service User 12 when referring to PB’s statement, she had been provided with all the papers and the allegations and had responded to the comments made by KI in relation to Service user 12. The Panel therefore considered it was in the interest of justice to allow Ms Sheridan to ask PB questions about Service User 12.
41. The Panel was of the view that whilst it was clear that the presentation of the assessment could be improved, for example in terms of the completion of proforma tick boxes, the information that formed the basis of the assessment was recorded. The risks and needs relating to the service user were identified and recorded and these were adequately reasoned to a conclusion. Accordingly, the Panel found Particular 1(c) not proved.
d. Service User 13 - proved
42. KI gave evidence about Service User 13, a 23 year old woman who suffered from depression, anxiety, asthma and sacroiliac joint dysfunction. She said the Registrant completed a bathing assessment on 1 June 2016 and considered writing a supportive letter to Home Choice. KI said there was a lack of clinical reasoning in the assessment to support any of the proposed options for equipment. KI was of the view that if adequate clinical reasoning had been applied by the Registrant, the options for equipment could have been different. She said that the Registrant was not clear in the assessment when describing Service User 13’s functional ability.
43. In her written representations, the Registrant said the service user was able to show her how she transferred herself to the bath board and thereafter lower herself into the bath, but that this caused her pain in her lower spine. Getting up out of the bath was also painful. The Registrant said that it was for these reasons that she decided it would be safer and less painful for the client to be granted an over bath shower. She said this was clearly documented in the assessment.
44. The Panel had sight of the assessment and agreed with KI that it was lacking in its clinical reasoning, as noted by KI. It noted that PB had to amend the recommendation and clarify the details of the Registrant’s earlier assessment in order to complete the shower specification form. The Panel was therefore satisfied that the clinical reasoning in this case was inadequate and it followed that the recording was also, therefore, inadequate.  The Panel thus found Particular 1(d) proved.
e. Service User 15 - proved
45. AW gave evidence about Service User 15, a woman in her late fifties who was obese, suffered from bi-polar disorder and had chronic obstructive pulmonary disease. She said that the Registrant carried out a home visit on 15 February 2016 and, on 18 February 2016, completed a Therapy Assessment. The Registrant recorded that the service user wished to have a toilet installed in the shower room she used on the ground floor. AW observed that the Registrant had suggested the service user swap bedrooms with her son so that her bedroom would be on the ground floor. AW took issue with this suggestion because, from all that the Registrant had recorded, it was apparent that the service user was mobile, could get up and down the stairs and was a member of a walking club. AW considered the assessment was therefore contradictory since there was nothing to stop the service user from using the downstairs shower (she had difficulties getting into the bath) and the first floor toilet. AW therefore questioned the Registrant’s clinical reasons for the recommendations she made.
46. In addition, AW said that the Registrant had recommended a bed lever because the client was having difficulty getting in and out of bed. However, the bed lever had a maximum operating weight of 20 stones and Service User 15 weighed 22 stones. Therefore the bed lever recommendation was inappropriate and could have broken whilst in use, putting the service user at risk of harm.
47. In her written representations, the Registrant said she had recorded that the service user was breathless on ascending stairs and that is why she recommended the bedroom swap with her son, who was on the ground floor. With reference to the bed lever, the Registrant said she was not being deliberately negligent and she regretted her error of judgement in not realising the limit of the equipment. She apologised to the client and also to the HCPC, but not to the Council whose treatment of her she regarded as “horrific.”
48. The Panel had sight of the assessment and accepted the evidence of AW that it was inadequate in its clinical reasoning and contained contradictions and erroneous information (about the bed lever). The Panel noted the matters listed by a colleague, SH, that either needed amending or further exploration and accepted that the assessment was deficient in these respects. The Panel found that the clinical reasoning was inadequate and it followed that the recording of those reasons was, therefore, inadequate. Accordingly, the Panel found Particular 1(e) proved.
f. Service User 22 - proved
49. KI provided detail about Service User 22, a 67 year old man with multiple sclerosis, who was referred for an OT assessment because he had become stuck whilst using his wall-mounted shower seat. KI said the Registrant visited Service User 22, but did not observe any transfers, which would have been appropriate to ascertain what the issues for the service user were. KI said the Registrant made a recommendation for equipment without any clinical reasoning to demonstrate that all options and alternatives had been considered and explored with the service user and his carers. The Registrant did not explore or document any risks with the solution being proposed. KI said that the Registrant was told by her then supervisor, that she had to return to observe Service User 22’s transfer and record observations. KI said the Registrant was then able to arrange for the appropriate equipment to be fitted, but this was only as a result of the intervention of her supervisor.
50. In her written representations, the Registrant said she had visited Service User 22 and observed his transfers from his then damaged shower seat. She recommended a horseshoe shower seat in discussion with the client. The Registrant did not comment on the adequacy or otherwise of her clinical reasoning and/or the recording of her clinical reasoning.
51. The Panel had sight of the assessment and accepted the evidence of KI that it was lacking in its clinical reasoning. This was supported by the fact that the Registrant had to return to the service user and observe his transfers in order to arrange for the appropriate equipment to be fitted. The Panel was satisfied that the clinical reasoning was inadequate and it therefore followed that the recording was inadequate. Accordingly, the Panel found Particular 1(f) proved.
g. Service User 27 - not proved
52. In relation to Service User 27, RG provided detail of the service user, a woman in her early sixties who suffered from a fungal skin infection. She said that the Registrant carried out a home visit on 19 August 2015 to carry out a bathing assessment. The Registrant recommended an over-bath shower be installed. As with Service User 1, RG said that it was not that the Registrant made a wrong recommendation necessarily, but that she had failed to provide the necessary clinical justification in the assessment. He said that she could have provided better clinical reasoning and improved her rationale for what she was recommending.
53. In her written submissions, the Registrant said she had documented the fungal infection the service user was suffering from and how this impacted upon her mental health and social life. She maintained that she had justified her clinical reasoning for recommending a shower.
54. The Panel noted that the Registrant assessed the service user’s requirements for a shower, rather than a bath, in relation to hygiene concerns. RG asserted that there was a requirement for her to be explicit about pulling all the information together to justify her recommendation and he said it would have been useful to have recorded what the Service User’s prescribed medication was for. The Panel’s view was that her implicit reasoning recorded on the assessment was adequate and was appropriately recorded.  It accepted that including an explanation of what the medication was for might have been useful, but considered that its absence did not make the assessment inadequate. The Panel therefore found Particular 1(g) not proved.

Particular 2
2. In relation to Service User 2, you:

a. Did not provide Service User 2 with a copy of the final Therapy Review - proved

55. AW told the Panel that Service User 2, a 42 year old man, had been referred to Occupational Therapy for a bathing assessment. She said the Registrant conducted a home visit to Service User 2 on 21 March 2016 and completed an assessment of her visit the following day. However, the Registrant did not provide Service User 2 with a copy of his Therapy Assessment Review, which prompted the service user to contact the Council on 30 June 2016 to ask for it. AW said, “Service Users are entitled to receive copies of the reviews and assessments that are written about them. This is in part to ensure that the documents accurately reflect the visits and accurately capture the service user’s needs. As Karen Bennetts did not send this therapy assessment to Service User 2, he was unable to judge for himself if his needs had been met…”
56. In her written representations, the Registrant said that Service User 2 was very indecisive and this made it difficult to work with him. She added that she often had to read utility bills to the client as he was unable to read and disclosed that he was dyslexic. She had then made suggestions about using a larger format on a colour contrasting background but the client told her he did not want a copy of the assessment. The Registrant said that she recognised that a client has a right to a copy of their assessment but that Service User 2 had declined having a copy. She suggested that the issue could have been managed professionally by means of a discussion of learning points with her supervisor.
57. The Panel found as a matter of undisputed fact that the Registrant did not provide a copy of the final Therapy Review, when clearly she should have done, and thus found Particular 2(a) proved.

b. Assessed the suitability of a property without Service User 2 being present - proved


58. AW said that Service User 2 indicated that he wanted to move property. She said it is common for an Occupational Therapist to view a potential new property to ascertain if it is suitable to meet the service user’s needs. She said that Service User 2 telephoned the Registrant and requested a joint visit with her to view the new property. However, on 11 May 2016, the Registrant visited the new property but without the service user present, as confirmed by the Therapy Review document.
59. In her written representations, the Registrant said that she decided to visit the property with a Housing Officer, but without the service user because she was expecting to go into the house whilst the family currently in residence were still there. She said Service User 2 had informed her that he experienced low mood and she had observed “high agitation, perfuse perspirations and impulsive behaviour.” She was also aware that he was prescribed benzodiazepine. She said for all these reasons she decided she could not take the risk of bringing him into a family environment. She said she was the one who was accountable for that visit and she stood by her decision which was supported by the Housing Officer.
60. The Panel found as a matter of undisputed fact that the Registrant visited the new property without Service User 2 and therefore found this Particular proved. However, the Panel considered the Registrant’s explanation for why she had not gone with the Service User to be reasonable and this would be reflected when considering the statutory ground.
c. Did not promptly send a letter to Homechoice regarding the bathing assessment you conducted for Service User 2 - proved

61. AW told the Panel that Home Choice is Cornwall Council’s social housing system where local residents can bid on social housing. An Occupational Therapist providing information relating to a service user’s needs to Home Choice could impact on that service user’s eligibility for re-housing and which priority banding they are allocated. AW said that, on 13 April 2016, she received an email from an administrative worker requesting that she contact Service User 2 because, “He has received his Home Choice Banding Letter and has been Banded E. He needs advice re bathing as Karen explained that she had sent a Home Choice Supporting Letter to get his banding increased. Home Choice reported to Service User 2 that they have not received anything.”
62. AW said that in a case note, dated 19 April 2016, the Registrant confirmed that she had not yet sent the letter to Home Choice. She then sent it the following day. AW said she “would have expected the letter to Home Choice to have been sent earlier, given that the assessment took place on [22] March 2016 and was not sent until April 2016.”
63. In her written representations, the Registrant said she did not respond initially to Home Choice because Service User 2 could not decide whether to move or to have a level access shower. Therefore, she could not write a supportive letter to provide an increase in House Banding due to the client’s indecisiveness.
64. The Panel accepted the evidence of AW that the Registrant should have sent the assessment earlier. It formed the view that the Registrant allowed herself, on occasion, to be led by the client to an unacceptable level and this clouded her judgement. On this occasion she should have sent the bathing assessment notwithstanding any prevarication by the client. The Panel therefore found Particular 2(c) proved.
d. Did not include the results of a bathing assessment in a letter to Homechoice, as was directed in supervision - proved

65. AW said the Registrant wrote a letter to Home Choice on 20 April 2016 in respect of Service User 2’s wish to move property. She said that within the letter there was a sentence that stated Service User 2 required a level access shower, but that the letter did not contain the outcome of the bathing assessment from 22 March 2016. In a supervision session on 29 March 2016, AW then instructed the Registrant to include the bathing assessment with the letter since otherwise it may have reduced Service User 2’s chances of having his banding increased and consequently his housing needs would not have been accurately prioritised. Notwithstanding that direction, at the next supervision meeting AW had to remind the Registrant for a second time of the need to send the bathing assessment, which the Registrant eventually did on 20 April 2016.
66. In her written representations, the Registrant acknowledged that she should have included a bathing assessment, although she could not say whether this would have increased his banding. She re-iterated that throughout her time working with Service User 2, he could not decide if he wanted to move or not. She said she provided him with: time to decide on a level access shower or to move; the option to continue with another Occupational Therapist; the option for the assessment to be sent out in a user-friendly format.
67. The Panel accepted the undisputed evidence that the bathing assessment was not included with the letter, that the Registrant was directed in supervision to send it and that she failed to do so until reminded for a second time. The Panel was satisfied that she was under a duty to send the bathing assessment because it may have affected Service User 2’s banding and also because she had been instructed by her supervisor to do so. The Panel therefore found Particular 2(d) proved.

Particular 3
3. In relation to Service User 3, you:

a. Recorded contradictory statements within the assessment - proved

68.  PB said that the Registrant carried out a bathing assessment of Service User 3 on 6 July 2015. In supervision with PB on 13. July 2015 he recorded, “Statements within the assessment are contradictory: ‘fluid mobility’ including ‘ascending descending the stairs’, ‘No difficulties noted with flexion from hip to knee’ ‘No problems with sit to stand’ ‘No problem with bed transfers’ then you state…’difficulty getting in and out of the bath due to inflexibility to knee joints.”
69. In her written representations, the Registrant said that what she meant by fluid mobility was to state that “Service User 3 had no gait pattern irregularity that was observed.” She said that “the client’s husband would be able to read the assessment and understand that there were no problems with mobility in motion as it was continuous. The term “inflexibility at the knee” could have been used to replace the original terminology. I would now document limited range of movement at the knee joint and state which side. This limited range of movement was only witnessed when Su3 attempted to transfer into the bath.”  The Registrant went on to say that PB “should be aware that a person may have difficulties in transferring on/off one piece of equipment, however may have no difficulties with other equipment or general mobility.”
70. The Panel noted the explanation provided by the Registrant but accepted that, on the face of it, the assessment did contain contradictory statements, as referred to by PB. It may well be the case that the husband would understand what was written, but it was also important that other health care professionals, who might have need to refer to the assessment, were able to understand it. The Panel therefore found Particular 3(a) proved.
b. Did not make a case recording of the assessment visit carried out on 6 July 2015 - proved

71. PB said that the Therapy Overview Assessment completed by the Registrant stated that she undertook the assessment of Service User 3 on 6 July 2015. However, there is no corresponding case note of this visit recorded on Mosaic.
72. The Registrant did not dispute this.
73. On the undisputed evidence that there was no case recording of the assessment visit carried out on 6 July 2015, the Panel found this Particular proved.

Particular 4
4. In relation to Service User 4, you:

a. Did not make a case recording of the home visit carried out on 31 July 2015 - proved

74. RG gave evidence about Service User 4, a woman in her early seventies who suffered from scoliosis of the spine. She required an access assessment because she wished to have safe access to her garden. He said the Registrant recorded, on 28 July 2015, that she had agreed to visit Service User 4 on 31 July 2015. The SWP FACE Review Form states the visit was conducted by the Registrant on 31 July 2015. However, there was no corresponding case record completed by the Registrant to show that she did complete the visit on that day. RG said “Karen Bennetts should have ensured a case record of her visit was completed. This avoids confusion for other members of the team if they are doing any work with Service User 4.”
75. In her written representations, the Registrant said, “The main factor in my defence is that the visit is documented. Ideally it should be on the case notes as well.”
76. On the evidence of RG, and the Registrant’s acceptance that she should have made a note, the Panel was satisfied that she should have made a case recording of the home visit she carried out on 31 July 2015, and was equally satisfied that no such record was made. The Panel therefore found Particular 4(a) proved.
b. Recorded an assessment which lacked sufficient detail and/or was contradictory in places - proved (in part)

77. RG said that the Registrant completed a Therapy Overview Assessment on 3 July 2015. From the records, RG, who had taken over at this point from PB, said that PB had identified a number of issues with the assessment. PB’s notes recorded, “There is no description in the main section of the assessment of what steps there are, heights, widths, is it feasible to ramp, that you consider physiotherapy a viable option to start with.”
78. RG said that the assessment contained a lack of detail and was confusing in places and it contradicted itself. He gave an example where there was reference to a Physiotherapist being involved who had given advice about Service User 4’s step access into the home. Then later in the assessment the Registrant states that the Physiotherapist will be assessing Service User 4 on the steps in a few months’ time. RG said that the Registrant should have adopted the ‘ladder approach’ and recorded her reasoning in the assessment. He said that her recommendation was not necessarily wrong, it was just not clinically recorded. He noted PB’s further comment on the assessment recommendation, “Why? Lack of rails/ height or depth of treads/ restriction in her range of movement in lower limb joints. Could she hold the rails and step down if support available for carrying her walking frame down?”
79. In relation to the assessment the Registrant said, “SU 4 was informed that graduated steps were not feasible. When I request a joint visit with a surveyor I respect their opinion and qualified knowledge. I was able to learn from the surveyor that my initial plan to graduate steps would have been impossible.” She went on to say, “It is clearly documented that a platform lift had been recommended by the surveyor. … This has been documented.”
80. In relation to Particular 4(b), the Panel noted that the Registrant did not directly respond to the criticisms made by RG about her assessment. On the basis of the evidence given by RG and the assessment itself, the Panel was satisfied that it lacked detail for the reasons given by RG and found this Particular proved on that basis. However, it was not persuaded that the assessment was contradictory since it was possible for the Physiotherapist to have been involved both in giving advice and returning later to assess the service user on the steps.

Particular 5
5. In relation to Service User 5, you:

a. Recommended equipment which was not suitable for and/or did not meet the needs of Service User 5 - not proved

81. RG provided evidence about Service User 5, a 37 year old woman who suffered from severe rheumatoid arthritis, fibromyalgia and an over-active thyroid. She lived at home with her boyfriend who provided caring assistance in order to meet her personal hygiene needs.
82. RG said that the Registrant conducted a bathing assessment of Service User 5 on 9 July 2015 and recommended that she trial a bath lift. RG said, “Karen Bennetts did not apply the ladder approach to Service User 5’s needs in that she did not document considering recommending an over bath shower with a swivel bather to assist Service User 5 getting in and out of the bath…it is my view that if Karen Bennett had correctly analysed Service User 5’s needs she would not have recommended the bath lift. She should have trialled a combination of over bath shower with swivel bather.” RG emphasised that “The goal of an Occupational Therapist is to assist the service user in gaining independence to carry out functions like bathing. This does not mean relying on a partner to help.” RG said that in his view the recommendation for a bath lift was incorrect and that the Registrant should have explored other options. He said that the consequence of the Registrant providing incorrect equipment meant that Service User 5 had to bathe at a local leisure centre or shower at a friend’s home. RG added that a fresh bathing assessment had to be carried out by another Occupational Therapist on 23 November 2015, which confirmed the bath lift was not suitable and which resulted in a level access shower being installed.
83. In her written representations, the Registrant said she had considered alternatives but dismissed them and she therefore disagreed with RG’s statement that she had not used the ladder approach. She said that Service User 5 and her boyfriend were really pleased with the bath lift and that it was not incorrectly prescribed.
84. The Panel was of the view that the Registrant’s recommendation for the trial of a bath lift in July 2015, was a reasonable, clinically reasoned response at the time of the assessment. The Panel was not satisfied that the HCPC had provided evidence that the Registrant, at the time of the assessment, had recommended unsuitable equipment. The Panel therefore found Particular 5(a) not proved.
b. Did not make a case recording of the assessment visit carried out on 9 July 2015 - proved
85. RG told the Panel how the Registrant recorded a case note on 3 July 2015 confirming a home visit had been arranged for 9 July 2015. However, there was no corresponding case record of the actual visit.  RG said, “It is poor practice not to make a contemporaneous note of a visit with a service user. From Cornwall Council’s point of view, if a home visit is not recorded on the Mosaic system, then it is viewed as not having taken place.”
86. With reference to the Case Note the Registrant accepted that she had made an error in not completing it.
87. On the evidence of RG, and the Registrant’s acceptance that she should have made a note, the Panel was satisfied that she should have made a case recording of the assessment visit she carried out on 9 July 2015, and was equally satisfied that no such record was made. The Panel therefore found Particular 5(b) proved.
c. Recorded an assessment which lacked sufficient detail and/or was contradictory in places - proved
88. With reference to the assessment form completed by the Registrant, RG said that she had made several basic errors within the report. He said she had left many of the tick boxes unchecked, she was not logical in her approach and she put contradictory information in the report. He provided numerous examples, such as the consent box not being checked, references to different types of mobility aid and recording ‘not stated’ in the section that asks ‘Have you had a recent fall?’ He pointed out that the most important section of the form is the ‘Assessment summary’ where the Occupational Therapist records what they are going to do for the service user. He said that the Registrant did not record that she had recommended a bath lift and that in the sub-section ‘Achievement’ the Registrant should have selected ‘Support not yet in place.’
89. In answer to this the Registrant said that whilst she had not gained written consent from the service user, there was implied consent given by the service user when they consent for a home visit and for Occupational Therapy intervention. She accepted that “explicit consent from obtaining a signature is more legitimate.” In answer to the issue about sticks she said the client had more than one stick. She said that she obtains full health details but may not directly ask a client if they have had a fall.
90. Having seen the assessment and heard from RG, the Panel was satisfied, for the reasons given by RG, that the assessment did indeed lack sufficient detail and was contradictory in places. Accordingly, the Panel found this Particular proved.

Particular 6
6. In relation to Service User 6, you recommended equipment that did not match the needs of Service User 6 and/or provided the service user with an assessment document which was inadequate - proved

91. In her evidence, KI detailed how Service User 6 was a 48 year old man who suffered from rheumatoid arthritis, osteoarthritis, fibromyalgia, spinal disc problems, paraesthesia, depression and anxiety. She said that the Registrant was tasked with carrying out an assessment. She completed a Therapy Assessment form, but did not then amend or review it in accordance with the requests made by PB in supervision. She said that Service User 6 consequently received an assessment that was of insufficient quality.
92. The Panel noted that PB had not dealt with Service User 6 in his statement and that the Registrant had not referred to this service user in her written representations when referring to the evidence of PB. However, after receiving legal advice from the Legal Assessor, the Panel had allowed this allegation to be explored with PB since he was the person who had been directly involved. His evidence on the issue was clearly relevant and the Panel noted that, although the Registrant had not commented on Service User 6 when referring to PB’s statement, she had been provided with all the papers and the allegations and had responded to the comments made by KI in relation to Service user 6. The Panel therefore considered it was in the interest of justice to allow Ms Sheridan to ask PB questions about Service User 6.
93. PB gave evidence that his key concerns with this document were as follows: he had noted that the desired outcome recorded did not match the needs of the service user; that it was plain from the assessment ‘bath for pain relief’ under ‘your needs’ did not tie up with the provision of the commode in the bedroom under desired outcomes; there was also no reference to a level access shower when it should have been listed under desired outcomes; and there was also a distinct lack of clinical reasoning throughout the assessment as to why a level access shower should be considered.
94. In her written representations when commenting on the evidence of KI, the Registrant said she disagreed with KI’s comments. She said she had provided Service User 6 with an assessment which he did not complain about. She said, “I am not sure what KI is insinuating by the fact that I have produced documents of insufficient quality documents, based on my refusal to constantly re-write.”
95. The Panel was satisfied on the basis of the assessment itself and the evidence given by PB about the content of the assessment, that it did not match the needs of Service User 6. For the reasons given by PB, and most notably the contradiction between the provision of bathing needs and reference to a commode, the Panel was satisfied that the assessment document was indeed inadequate. The Panel thus found this Particular proved.

Particular 7
7. In relation to Service User 7, you:

a. Did not make a case recording of the assessment visit carried out on 15 July 2015 in a timely manner - proved

96. RG provided evidence about Service User 7, whom he described as a [78] year old man who suffered from rheumatoid arthritis, type-2 diabetes and atrial fibrillation. He said that the service user had been referred to Occupational Therapy for a bathing assessment because he wanted to have his home adapted to have a level access shower fitted. RG detailed how the Registrant recorded on the FACE Occupation and Daily Activities Assessment form that she conducted a home visit with Service User 7 on 15 July 2015. However, the case note was not entered onto the Mosaic system (the computer recording system used by the Council) until 6 August 2015. RG said “It is important for accuracy that a case record is completed in a timely manner. Ideally a case record should be entered onto the Mosaic system the same day as a home visit is conducted, or as soon after as possible. Leaving a gap of around three weeks is too long.”
97. The Registrant, in her written representations, acknowledged that “It is preferable that case notes should be entered on time.” She added that this is what she would aim to do.
98. On the basis of the undisputed evidence that the case recording was not completed for a period of three weeks, the Panel was satisfied that this Particular was made out. The Registrant was clearly under a duty to make such a record and failed to do so within a timely manner.
b. Recorded an assessment which lacked sufficient detail and/or was contradictory in places - proved
99. RG said that the assessment completed by the Registrant was quite contradictory in places. He said that the Registrant recorded that Service User 7 did not want equipment, but wanted a level access shower. RG pointed out that the service they provide is not about what the service user wants, but rather about what the service can do to meet the client’s needs. He said that Service User 7 was recorded as having declined a swivel bather as he was using grab rails, which are discouraged as they are considered unsafe. He went on to say that the Registrant had recorded that she did not observe the service user having difficulties when transferring to the chair or getting in or out of the shower and his bed transfers were satisfactory. However, later on in the assessment she stated that Service User 7 was having difficulty, but it was unclear what she was referring to.
100. RG added that the Registrant had noted in the assessment that Service User 7’s wife was too anxious ‘getting in and out of the bath’. There is no further explanation within the assessment as to why she is anxious or whether she has any physical impairment that might explain it. RG said that in the section ‘Are you currently recovering from illness, injury or associated treatment’ the Registrant had not recorded details of Service User 7’s right hip replacement.
101. In her written representations, the Registrant said that she was merely stating what the client had told her. She said she was aware that a client does not automatically get what they want. She said that Service User 7’s wife did not present with mobility issues, but was more anxious. The Registrant said that the wife declined to take part in the assessment of getting in and out of the bath and she regretted not documenting that.
102. The Panel had sight of the assessment and accepted the clear evidence provided by RG. It was satisfied on that evidence that the assessment contained very little detail and was contradictory with reference to transferring being without difficulty, on one page of the assessment, and then the later reference to there being a difficulty. The Panel therefore found this Particular proved.
c. Recorded an assessment that lacked clinical analysis of Service User 7’s situation - proved

103. RG told the Panel that the Registrant had recorded that Service User 7 had declined the offer of bathing equipment, but wanted a level access shower. In the ‘Summary of needs and outcomes’ the Registrant had recorded a ‘level access shower.’ RG said, “If Service User 7 could safely meet his personal hygiene needs by using equipment, then it would not be appropriate for an OT to have recommended a level access shower.” He added, “From this assessment it is unclear as to what Karen Bennetts is recommending for Service User 7 and why. There also is no conclusion drawn as to what next steps are to be taken. Without the clinical analysis and use of the ladder approach it is difficult for anyone else working with Service User 7 to understand Karen Bennett’s rationale as to why she has done certain things.”
104. In her written representations, the Registrant said that she did use the ladder approach, but that if a client declines to trial equipment she cannot force them to do so.
105. The Panel considered the assessment and the comments made by RG and was satisfied that the assessment lacked clinical analysis of Service User 7’s situation for the reasons given by RG. RG was a senior practitioner who gave persuasive evidence. The Panel therefore found Particular 7(c) proved.

Particular 8
8. In relation to Service User 8, you did not make a case recording of the joint home visit carried out on 29 July 2015 and/or the further actions to be taken in the case - proved

106. RG provided evidence about Service User 8, a man in his late eighties suffering from chronic obstructive pulmonary disease, cancer, glaucoma, dementia and was catheterised. He said there was a case record dated 27 July 2015, stating the Registrant had spoken to Service User 8’s daughter on the telephone and had booked a joint home visit on 29 July 2015. RG said there was no entry on Service User 8’s Mosaic case records recording that the Registrant undertook the joint visit or a record of the further actions to be taken in his case. RG said, “If there is no case record of Karen Bennetts conducting a home visit with Service User 8, then anyone else working on the case would not know that one had taken place. It is important that all contact with service users is recorded to see the journey of the service user to ensure we are meeting our obligations to provide them with the equipment and adaptations they require.”
107. RG added, “I would expect there to be a case record stating what further actions Karen Bennetts intended to take further to the home visit she conducted. This could have included the equipment that she planned to trial with Service User 8, or referral for adaptations to be undertaken.” He said that with this not being recorded it could have caused unnecessary delay for a service user whose needs were particularly time sensitive.
108. In her written representations, the Registrant said, “I refuse to keep commenting on case record entries. The focus for me is that I was struggling to get through the constant re-writing of assessments which never reached the approval of supervisors.”
109. The Panel accepted the evidence of RG that the Registrant should have made an entry of her visit on 29 July 2015 and also that she should have recorded what further actions were to be taken or were planned. The Panel had the record and it was clear these matters were not recorded. Accordingly, the Panel found Particular 8 proved.

Particular 9
9. In relation to Service User 9, you:

a. Did not consider adequately, or at all, the service user’s bathing needs - proved

110. PB gave evidence about Service User 9, who was in her mid nineties, registered blind, used a wheelchair and had heart disease and osteoarthritis. He said the Registrant carried out an assessment of the service user for mobility and access for the service user to be able to get in and out of her back garden. He said there was no referral or request for a bathing assessment. In the Registrant’s assessment, it stated that the carers manage Service User 9’s bathing needs and therefore a bathing assessment was not needed.
111. PB said that he discussed this assessment with the Registrant in a supervision session on 23 June 2015. He said he had reviewed the assessment and suggested, “As the carers are strip washing and [Service User 9] has regular bouts of diarrhoea did you consider showering facilities? If you are submitting DFG [Disabled Facilities Grant] for ramping and they are financially eligible it would be advisable to look at it all at the same time.” PB said this was not done by the Registrant, resulting potentially in an unmet need.
112. In her written representations, the Registrant said that Service User 9 was referred to her for access needs and that she did consider the provision of a level access shower. She said she discussed this with the client and her daughter, but both were happy with the carers attending to her personal hygiene needs and thus did not want a level access shower. She added, “I do not know if I documented it on a case note as I do not have access to case notes. I recall the Su9 reporting her main concern was not getting out of the house. I reported the main concerns appertaining to the client. It is with regret that I did not include this conversation in the main assessment.”
113. The Panel had the assessment and could see that nothing was recorded about the service user’s bathing needs and indeed the Registrant accepted as much. On the evidence of PB the Panel was satisfied that the bathing needs should have been recorded and therefore found Particular 9(a) proved.
b. Did not schedule a review of Service User 9 - proved
d. Did not promptly submit the major adaption request - proved
114. The Panel considered Particulars 9(b) and (d) together because they were inextricably linked.
115. The Panel heard how the Therapy Overview Assessment was conducted on 15 June 2015 by the Registrant. PB said that on 8 March 2016, he took this case over from the Registrant and realised she had not scheduled a review for Service User 9. He noted that on 18 January 2016 a case record, completed by a colleague SH, recorded that Home Solutions had not received the referral in relation to Service User 9 and that the relevant form “has now been submitted as Urgent.” It was the HCPC’s case that there should not have been such a delay between the visit on 15 June 2015 and the major adaptation request being sent.
116. PB said that a review was set up because the Registrant had not done this as she should have in June 2015. PB said that the review should have been scheduled for when the ramp to Service User 9’s home had been put in place to ensure it was correct. However, because the major adaptations form had not been submitted, the work had not been started. PB said that “in the majority of cases a review should be selected by an Occupational Therapist as an outcome from a therapy session in order to review any proposed input.” PB said that the failure to submit the major adaptation request and to schedule a review meant that Service User 9 “remained unable to safely enter and leave her property, which could have had a significant impact on he health and well-being and also her safety as she was being carried by family when she wanted to go outside.”
117. The Registrant had not commented on the allegation about a lack of a review. In relation to the delay she said, “The delay was undoubtedly connected to the punishing repeating of work that I was made to complete.” She added, “Had I received software fit for practice (read & write gold medical) this would have removed the need for this discriminatory process to mark my work.”
118. The Panel accepted the unchallenged evidence of PB that there should have been a review scheduled. It was clear from the record that no such review was scheduled and accordingly the Panel found Particular 9(b) proved.
119. It was also clear from PB’s evidence, and the records, that there had been a seven month delay in the submission of the major adaptation request. The Registrant accepted that there had been a delay. She appeared to blame this in part on the software she had been provided as part of the reasonable adjustments provided to her, following her assessment by the ATW team. All the witnesses had been asked during their evidence whether the Registrant had ever raised any  issues about the software she had been provided with and all said that she had not. The expert witness was asked what differences there were between the software provided to the Registrant and the ‘Read & Write Gold medical’ software. She was aware of both and said that in her opinion there was very little difference. The Panel considered a delay of seven months constituted not submitting the major adaptation request promptly and found Particular 9(d) proved.
c. Did not make a case recording of the assessment visit carried out on 15 June 2015 - proved

120. PB said that the Major Adaptation form completed by the Registrant on 25 January 2016 stated that she conducted a home visit to Service User 9 on 15 June 2015. However, he said, there was no corresponding case record in Service User 9’s case notes for this visit. PB said that, “If a record of a home visit is not on the system, then as far as the rest of the team is concerned it did not happen. Multiple workers may be dealing with an individual at the same period of time. The records should accurately reflect everything that has happened.”
121. In her written representations, the Registrant said, “I am not defending my actions if I have failed to make a case note …” She added, “I believe failure to make a case note should not be interpreted that I am a risk to the public.”
122. The Panel accepted the evidence of PB that the Registrant should have recorded the home visit and had not done so, as was clear from the records. The Panel therefore found Particular 9(c) proved.

Particular 10
10. In relation to Service User 10, you did not undertake and/or record undertaking a review before closing the case - proved
123. PB provided evidence about Service User 10, an elderly man who suffered from Meniere’s disease, had diabetes, lumbar stenosis and an under active thyroid. He was also a wheelchair user. PB said that the Registrant conducted a home visit, on 1 June 2015, because the service user’s home did not permit safe access for him to enter or leave the house. PB said, “The initial assessment form completed by Karen Bennetts in relation to the home visit which took place on 1 June 2015 covers all the personal details of Service User 10 any transfer issues he has, and a record of his needs. From there Karen Bennetts should have completed a review form. This is used to ensure that any interventions, equipment or adaptations that have been recommended have been completed or provided, and the service user’s needs have been met. This form should be completed before a case is closed. These documents are all stored on the Mosaic system. There is no record that Karen Bennetts sent the assessment form to Service User 10, no record that a review had taken place, and no record that Service User 10 had been informed his case had been closed.”
124. PB added that, “Because none of these forms were sent to Service User 10, he would not have known what was going on. The review form tells the service user how to get in touch in the future if they need more assistance.”
125. In her written representations, the Registrant said that she had been assured by AW that “not all assessments required a review.” However, she goes on to say “I believe it is preferable to send out reviews to all cases. This summarises Occupational Therapy intervention, what has taken place on the previous visit and any future outcomes. I agree case notes do give the MDT clear communication on the individual client. I worked for CC for over three years. The vast majority of my case notes were recorded.”
126. The Panel accepted the evidence of PB, as supported by the records, and was satisfied, on the balance of probabilities, that the Registrant did not undertake a review, as she should have done, before closing the case. The Panel thus found Particular 10 proved on that basis. Clearly if something is not done, it cannot be recorded.

Particular 11
11. In relation to Service User 11, you did not undertake and/or record undertaking a review - proved

127. PB said that Service User 11 was a man who was HIV positive and had suffered a heart attack. He had been in a coma and had a brain injury as well as incontinence issues. PB said that according to Service User 11’s case notes, there was no record of a review document being sent to him prior to the case being closed on 2 July 2015. PB added, “A review document should be completed before a case is closed in order for Service User 11 to know that this has happened, so if he was of the view that his needs had not been met, he could have raised this with Karen Bennetts.”
128. The Registrant did not provide any representations in relation to this allegation involving Service User 11.
129. The Panel accepted the evidence of PB, as supported by the records, and was satisfied, on the balance of probabilities, that the Registrant did not undertake a review, as she should have done, before closing the case. The Panel thus found Particular 11 proved on that basis. Clearly if something is not done, it cannot be recorded.

Particular 12
12. In relation to Service User 11, you sent a housing letter instead of a housing support statement - proved
130. PB said that there was a case note dated 2 July 2015 stating, “Letter sent for rehousing to Rachel Lytham at home solutions on 30/06/15. Case closed to OT.” PB added “It is not a housing letter to Home Solution that should have been sent. It is a ‘housing support statement’ which should have been sent to Home Choice - this document provides the OT’s professional view as to why Service User 11’s banding should be increased. Home Solutions provide adaptations to people’s homes. Home Choice decide on people’s needs and based on that which banding they should be allocated in order for them to bid to move to a new local authority house.’
131. PB said that as a result of this error Service User 11’s potential re-banding would have been delayed which means there may have been a delay in meeting his health and well-being needs.
132. In her written representations, the Registrant said, “… this error could have occurred from my dyslexia and recollecting the correct term. I apologise for this error.”
133. The Panel accepted the undisputed evidence that the Registrant sent the housing letter to Home Solutions when she should have sent a housing support statement to Home Choice. It therefore found this Particular proved.

Particular 13
13. In relation to Service User 13, you did not adequately record the bathing assessment - proved

134. KI gave evidence about Service User 13 and the issues she had that required a bathing assessment. She said “the Registrant was not clear in her assessment when describing Service User 13’s functional ability.” She said that what was recorded did not make sense without the outcome the Registrant was recording. KI said there was a lack of clinical reasoning in the assessment to support any of the proposed options for equipment and that the Registrant had not adopted the ‘ladder approach’. KI said that the Registrant was aware of the ‘ladder approach’ which was a fundamental aspect of the assessments which the Service carried out.
135. In her written representations, the Registrant described what the service user was able to do and what caused her pain when getting in and out of the bath using a bath board. She said for these reasons she decided it would be safer and less painful for Service User 13 to be granted an over bath shower. The Registrant maintained that this was clearly documented in the assessment.
136. The Panel had sight of the assessment and accepted the evidence of KI that the Registrant had not been clear in her assessment. It did not accept the Registrant’s assertions that the bathing assessment was clearly documented as this was not supported by the assessment. It noted the concerns raised, and referred to in the records, by the Registrant’s colleague SH “What I need to ask is can she use the bath? We would not provide an over-bath shower for someone because they prefer to shower. If this is the same case you talked to me about in the office you said she couldn’t get down into the bath - this needs to be documented as this is your clinical reasoning for recommending an over-bath shower. If she has no continence issues bathing is perfectly hygienic.” SH also queried whether a ‘bath lifting seat’ or a ‘grab rail’ had been tried as part of the assessment. SH said “An over-bath shower cannot be recommended because someone believes it is not hygienic to bath.” On the basis of this evidence the Panel was satisfied that the Registrant had not adequately recorded the bathing assessment and found this Particular proved.

Particular 14
14. In relation to Service User 15, you ordered equipment which was not suitable for Service User 15 - proved

137. AW gave evidence about Service User 15, a woman in her late fifties who was obese, suffered from bi-polar disorder and had chronic obstructive pulmonary disease. She said that the Registrant carried out a home visit on 15 February 2016 and on 18 February 2016 completed a Therapy Assessment. AW said that the Registrant had recommended a bed lever because the client was having difficulty getting in and out of bed. However, the bed lever had a maximum operating weight of 20 stones and Service User 15 weighed 22 stones. Therefore the bed lever recommendation was inappropriate and could have broken whilst in use, putting the service user at risk of harm.
138. In her written representations, the Registrant said she was not being deliberately negligent and she regretted her error of judgement in not realising the limit of the equipment. She said she was sorry for the client.
139. The Panel had sight of the assessment and accepted the undisputed evidence of AW that the Registrant had recommended a bed lever that was not suitable for Service User 15 because her weight exceeded the maximum operating weight of the lever. Accordingly, the Panel found Particular 14 proved.

Particular 15
15. In relation to Service User 16, you did not submit the major adaptation paperwork in a timely manner - proved
140. AW provided detail about Service User 16, a woman in her early sixties who suffered from osteoarthritis, fibromyalgia, neuropathy, arthritis, type-2 diabetes, asthma, depression, incontinence and irritable bowel syndrome.  She said the Registrant carried out home visits to Service User 16 on 11 and 17 February 2016. She said that the Registrant completed records that she had trialled a swivel bather and bathboard, but neither were appropriate to meet the hygiene needs of the service user. Accordingly, the Registrant was going to recommend a disabled facilities grant (DFG) for a level access shower. AW said that this was considered a major adaptation to Service User 16’s home and the necessary form should have been sent off within a week. However, the form was not sent until 21 March 2016. AW was particularly surprised at this because she had raised it in supervision with the Registrant on 19 February 2016 and again on 1 March 2016. AW did not consider this to be acceptable because it meant that Service User 16 had to wait longer than necessary for the shower she needed to meet her needs.
141. In her written representations, the Registrant said, “In answer to this, I can state with confidence that the entirety of these problems associated with all my work being produced on time, was out of my control.” She blamed AW and others for acting in a discriminatory manner towards her. She said her work was being constantly checked for spelling, grammar, punctuation and clinical reasoning in order to meet her supervisors’ approval. She said her supervisors were not supporting her dyslexia and that her ideas of clinical reasoning were “totally thwarted.” She added, “I was in fact paralysed from using my clinical reasoning, as I was always deemed wrong and incompetent. For that reason, I did not control the length of time it took to send out work for Major/Minor Adaptions, Assessments, Assessments or Reviews. Had any of my supervisors including [AW] provided read & write gold, further training and made reasonable adjustments not necessitating cost, there would have been a stark improvement.”
142. The Panel noted the issues raised by the Registrant and it was clear that she felt she was not being treated fairly. However, the Panel had already indicated that, on the evidence it had heard, including expert evidence, it was satisfied that reasonable adjustments had been made to enable the Registrant to perform competently in light of her dyslexia. All the witnesses said that the Registrant did not raise any concerns about the adjustments that were put in place or the software provided and the expert said that the adjustments were reasonable. Indeed, the recommendations the expert suggested after her assessment in large part mirrored those put in place after the ATW assessment. That said, the Panel accepted that some delay was occasioned by the document checking structure imposed by the Council. KI said, “the supervision and document checking structure imposed by CC on Karen Bennetts would have contributed to the delay, as her supervisor had to be satisfied the documents were of a suitable quality to send to Service User 16.”
143. The Panel accepted the undisputed evidence that the Registrant carried out the home visits on 11 and 17 February 2016, but did not submit the major adaptations form until 21 March 2016, a period of over a month. The Panel also accepted the evidence of AW that the form should have been sent within a week. Whilst not the greatest of delays, it did not constitute submitting the major adaptation paperwork within a timely manner. The Panel therefore found Particular 15 proved. However, when considering the statutory grounds, the Panel would take into account the comments by the Registrant and KI about the impact of the supervision and document checking structure imposed on the Registrant.

Particular 16
16. In relation to Service User 17, you:

a. Acted outside the scope of your practice, in that you provided Service User 17 with dietary advice - proved

144. KI provided evidence about Service User 17, a 73 year old woman who suffered from osteoarthritis, fibromyalgia and spondylitis rheumatica. She said the Registrant completed a Therapy Assessment in respect of Service User 17 on 25 February 2016 and under ‘Continence Concerns’ the Registrant had recorded, ‘OT advised drinking fruit juice and eating fruit and vegetables as much as possible.’ Under ‘Managing Nutrition’ the Registrant had recorded, ‘[Service User 17] reports she has difficulty in swallowing and has had an episode of choking…OT has discussed the need to finely dice food.’ A colleague, SH, commented, ‘I would not be giving advice on this without SALT input. May cause greater issues with ingesting and choking.’
145. In her written representations, the Registrant said that she “did not provide dietary advice in which I have gone beyond my scope of practice.” She said that under ‘Managing Nutrition’ she had noted that the client had discussed episodes of choking and the Registrant suggested discussing it with her GP or that she was willing to make a referral to a Speech and Language Therapist (SALT). The Registrant said she suggested to the service user that she finely dice her food. She said the reference to eating fruit and vegetables was just informal information that she chose to include in the assessment as the service user reported constipation.
146. The Panel did not consider the reference to eating fruit and vegetables amounted to dietary advice, but rather just common sense. However, given the reference to Service User 17 having difficulties with swallowing, the Panel did consider the Registrant was acting outside the scope of her practice by suggesting the service user cut up her food finely. On this basis the Panel found Particular 16 proved.
b. Did not record a risk assessment within the therapy assessment in relation to a straight stair-lift - proved

147. KI gave evidence about Service User 17 and stated, “Karen Bennetts recommended a curved and straight stair-lift. The therapy assessment form does not contain a risk assessment related to provision for a straight stair-lift if the curved stair-lift was declined.” KI said that the Council did sometimes provide a straight stair-lift where a service user was ineligible for a grant for a curved stair-lift, but it was important that if that course were to be followed, a risk assessment had been carried out to ensure it was a safe option. She said it was that reassurance which was lacking from the assessment recorded by the Registrant.
148. In her written representations, the Registrant said that she recommended the curved stair-lift because “this would have provided maximum safety.” She believed the service user would not have qualified for a grant and so would have had to pay for the curved stair-lift, whilst a straight stair-lift would not incur a charge.
149. The Panel had sight of the assessment and could see there was no risk assessment within the therapy assessment in relation to a straight stair-lift. The Panel was satisfied on the evidence of KI that there should have been such a risk assessment in order to know whether Service User 17 could manage the remaining stairs if a straight stair-lift were installed. KI said that without such an assessment it could not be known if a straight stair-lift would present any risk of harm to the service user. The Panel therefore found this fact proved.

Particular 17
17. In relation to Service User 18, you did not record an adequate risk assessment within the therapy assessment - proved

150. KI provided the Panel with evidence about Service User 18, an 81 year old woman who had heart problems and was referred for an assessment of her mobility on the stairs. That assessment was carried out by the Registrant on 25 February 2016. AW provided the Registrant with feedback on that assessment during a supervision meeting on 1 March 2016 and asked the question, “What is the nature of the risk?”
151. In her written representations, the Registrant said that SH had “repeatedly requested I alter my assessment for the seventeenth time. This is an example of the intimidation and ridicule taken to hinder my work.”
152. The Panel noted that the Registrant did not specifically respond to this allegation. It had sight of the assessment and could see that no risk assessment had been recorded. The Panel was satisfied on the evidence that the Registrant should have recorded a risk assessment and accordingly it found Particular 17 proved.

Particular 18
18. In relation to Service User 19, you did not make and/or record making a referral for physiotherapy - dismissed

153. RG gave evidence about Service User 19 and said he had been unable to find any record of the referral for physiotherapy. However, he was then taken to an email exchange provided by the Registrant, between the Registrant and CF, a member of the admin team. RG accepted that it was clear from that exchange that the referral had been made, but said he had responded to the documents that had been before him at the time.
154. In light of that evidence Ms Sheridan stated that this Particular was no longer supported by the evidence and she invited the Panel to dismiss it.
155. The Panel accepted that there was no longer any evidence to support this allegation and therefore dismissed it.

Particular 19
19. In relation to Service User 20, you did not submit the major adaptation paperwork in a timely manner - proved
156. KI gave evidence about Service User 20, a 78 year old man with chronic obstructive pulmonary disease, who was referred for “an assessment on the stairs.” The Registrant completed a therapy assessment but KI said that she did not complete the recommendation for a stair-lift in a timely manner and did not follow the correct process. KI said this resulted in a delay in Service User 20 receiving the necessary provision.
157. In her written representations, the Registrant said that she had pointed out to SH that she was unaware of the process for Council properties regarding stairlifts and she believed this was due to a lack of training.
158. From the records it was apparent that the Registrant had been directed, during a supervision session on 4 May 2016, to complete the major adaptation for service User 20. The Adaptation request was started on 28 April 2016 but not completed until 26 May 2016. The Panel was satisfied that this did not constitute submitting the paperwork in a timely manner and therefore found this Particular proved. However, as with Particular 15, the Panel noted that the delay was in part due to the supervision and documentation regime put in place for the Registrant and also that the Registrant had not had training in the specific form of adaptation. These were matters which would be revisited when considering the statutory ground.

Particular 20
20. In relation to Service User 23:

a. You did not make a case recording of the home visit carried out on 31 July 2015 - proved

159. RG gave evidence about Service User 23, a man who suffered from angina, Alzheimer’s disease, transient ischaemic attacks, was incontinent and had had a heat attack. RG said that the Registrant visited Service User 23 on 31 July 2015 to carry out a bathing assessment. This visit was documented in the assessment form and the Statement of Need, but there was no corresponding case record of the visit. Without such a record, any other member of staff who looked up Service User 23’s case records, would have been unaware that this visit had taken place.
160. In her written representations, the Registrant said she could not discuss the case record as she did not have access to it.
161. The Panel accepted the evidence of RG, as supported by the case records and could see that no record of the visit had been recorded by the Registrant. It therefore found Particular 20(a) proved.
b. The assessment form you completed lacked sufficient clinical reasoning for the recommendations made - proved

162. RG said that the Registrant’s assessment did not have sufficient clinical reasoning to demonstrate why she had recommended a level access shower and also why it was recommended on the ground floor when the bathroom was upstairs. He was not saying that such a recommendation was wrong, but rather that it was the lack of clinical reasoning in the assessment which was the issue. RG said that in supervision he asked the Registrant what was her reasoning in deciding a level access shower was appropriate and why downstairs. They needed to know why the service user could not go upstairs. In his view it was again a lack of clinical reasoning by the Registrant.
163. In her written submissions, the Registrant explained why she had reached the conclusion that she had. She did not comment on the allegation of the assessment lacking sufficient clinical reasoning for that recommendation.
164. The Panel had sight of the assessment and accepted the evidence of RG that it lacked sufficient clinical reasoning for the recommendations made. The Panel considered it to be particularly important to provide detailed reasoning where a family needed to understand the basis for the recommendation. The Panel thus found this Particular proved.

Particular 21
21. In relation to Service User 24, you:

a. Did not make a case recording of the assessment visit carried out on 30 July 2015 in a timely manner - proved

165. In his evidence RG referred to Service User 24, a man in his early seventies who suffered from respiratory failure, emphysema, asbestos on the lungs, osteoporosis of the spine and diverticulitis. He said that the Registrant carried out a home visit on 30 July 2015. This information was recorded on the Statement of Need and the assessment, but was not recorded on case records until nine days later. RG said that it was widely known within the Council that case records should be made the same day, or the next day if the practitioner is out of the office. He said that he had discussed time scales with the Registrant during supervision and that it would have been communicated to her during her induction.
166. In her written representations, the Registrant said, “The case note entry was late by 9 days. The case note was still entered.”
167. The Registrant carried out the visit and was therefore under a duty to record the visit in the case records in a timely manner. The Panel did not consider 9 days to be in a timely manner. In the intervening 8 days none of her colleagues would have known that she had carried out a visit. The Panel therefore found Particular 21(a) proved.
b. Did not capture and/or record adequate details of the property - not proved

168. RG said that the Registrant did not record all the correct details of Service User 24’s property when recommending adaptations to be made to his home. He accepted that the biometrics were substantially completed, but said there was one measurement missing that could affect what was recommended. It was the measurement from the back of the spine to the front of the feet which was missing. RG accepted that all the other biometric measurements were present. RG said the measurement was missing from the Registrant’s first draft but did appear in the final draft after she had had supervision with him.
169. In her written representations, the Registrant said that she disagreed with the assertion that she had not described the correct details of the home. She said the property was extensive and that when viewing a larger property it becomes necessary to focus on the areas of the house which have been identified as problematic for the client. She added that biometrics had been recorded.
170. The Panel was not clear about how, and in what way, the details recorded about the property were insufficient. It had been directed to one missing biometric measurement but nothing else that was said to be deficient. The assessment clearly had some detail about the layout of the property and the Panel was not satisfied, on the balance of probabilities, that the Registrant had failed to capture and record adequate details for the property. The Panel therefore found Particular 21(b) not proved.

Particular 22
22. In relation to Service User 26, you:

a. Did not make a case recording of the disclosure of abuse by Service User 26 and/or the safeguarding alert raised in relation to the disclosure in a timely manner - proved (in part)

171. VI gave evidence, having conducted a home visit on 14 October 2014, that the Registrant became aware of a safeguarding concern in respect of Service User 26’s adult daughter. However, the Registrant did not write up a case record of this visit until 22 October 2014. VI said ‘Safeguarding concerns should be raised immediately with the safeguarding unit at Cornwall Council…to raise a concern, Karen Bennetts should have completed a form which is available online…[she] should also have recorded her concerns in the case record relating to Service User 26 in a timely manner. This is usually considered to be the same day or at least by the next day.’
172. In her written representations, the Registrant said with reference to the safeguarding issue that she had made a record on Service User 26’s Case Notes relating to the day of the visit entitled “Possible Safeguarding Alert”. In the note she had detailed the concern and recorded that she had contacted the Access Team about it. The Registrant said that the Manager of the Access Team decided that the situation “did not warrant a safeguarding alert as it would be acted on.” The Registrant said this was the process that VI had advised her to follow and that VI had never at any point showed her any online forms to complete. If she had been aware of an online form she would have completed it. The Registrant said that she did raise her concerns immediately with the appropriate team.
173. The Panel had sight of the Case Note completed by the Registrant of her visit to Service User 26. The note makes it clear that the Registrant had identified a safeguarding issue and had reported it the same day to the Access Team. However, the record itself was not entered until 22 October 2014 and had, therefore, not been entered in a timely manner which, the Panel accepted, should have been on the day or the next day. The Panel therefore found Particular 26(a) proved insofar as the case recording of the disclosure of abuse was not done in a timely manner.
174. The Panel was not persuaded that the Registrant had failed to make a record of the safeguarding alert raised in a timely manner. It had not been directed in evidence to the specific means whereby a safeguarding alert should be raised, other than a reference to an online form. The Panel was not shown any information about the form and it noted the Registrant’s comments that she had not been trained to use such a form. The Panel therefore did not find that part of Particular 22(a) proved.

b. Did not submit the recommendation for a disabled facilities grant in a timely manner - proved
175. VI said that when the Registrant visited Service User 26 on 14 October 2014, she assessed that Service User 26 required a level access shower in order to meet her personal bathing needs. The following day she completed a DFG form, but didn’t send the form to the Housing Adaptations Team until some ten months later on 6 August 2015. VI said, “Karen Bennetts should have sent the form to the housing adaptations team to process within seven days of the home visit…Without a DFG being sent, the process does not get started and none of the work needed to adapt Service User 26’s home would have been started. Karen Bennetts inaction meant that Service User 26’s case was delayed and she would not have been able to independently meet her personal bathing needs in the interim.”
176. The Panel noted that RG had not dealt with Service User 26 in his statement and that the Registrant had not referred to this service user in her written representations when referring to the evidence of RG. However, after receiving legal advice from the Legal Assessor, the Panel had allowed this allegation to be explored with RG since he was the person who had been involved in an email exchange between the Registrant and himself. His evidence on the issue was clearly relevant and the Panel noted that, although the Registrant had not commented on Service User 26 when referring to RG’s statement, she had been provided with all the papers and the allegations and had responded to the comments made by VI in relation to Service user 26. The Panel therefore considered it was in the interest of justice to allow Ms Sheridan to ask RG questions about Service User 26.
177. RG was taken to an email exchange between himself and the Registrant, where the Registrant stated she had been going through her cases and found that in relation to Service User 26 the original documentation had not been received by the adaptations team. She said she had marked it as urgent due to “the original document being lost in the system.” On looking into this RG said he was satisfied that it had been the Registrant’s fault in not sending the documentation, but he said she would have been “under a lot of pressure and he was pleased that she had picked it up.” He said “it was both brave and professional of her to have done so and showed honesty and integrity on her part.”
178. The Registrant said in her written representations that she could not remember what had happened to the original referral.
179. The Panel accepted the evidence given by RG who had been very fair in his evidence and spoke positively about the Registrant’s behaviour in relation to this discovered omission. On the balance of probabilities, the Panel was satisfied that the Registrant had omitted to submit the recommendation for a DFG at, or around, the time of the assessment in October 2014. It was not, therefore, sent until 6 August 2015, some ten months later and this clearly did not constitute being submitted in a timely manner. Accordingly, the Panel found Particular 22(b) proved.

Particular 23
23. The assessment form you completed in relation to Service User 29 lacked sufficient detail and/or was contradictory in places - proved (in part)
180. PB provided evidence about Service User 29, a woman suffering with fibromyalgia, a hiatus hernia and pain and fatigue whilst she recovered from a fracture to her right ankle. He said that the Registrant conducted a home visit on 24 April 2015 to complete a bathing assessment. PB said that the assessment form did not contain the professional notes expected from an Occupational Therapist completing a bathing assessment. PB said that much of the content discussed Service User 29’s past, for example being in a choir and making quilts, none of which he considered to be relevant to a bathing assessment. He said what the assessment lacked was clinical information. PB said that Service User 29 needed the bathing assessment because she was using a perching stool to transfer into the bath. The Registrant records ‘discussing using a bath lift with Service User 29 who is in agreement to trial this next week’. However, according to PB, the Registrant should have used the ladder approach to determine which equipment would have best assisted Service User 29 in meeting her needs to safely transfer into the bath, i.e. consideration of trialling a bath board or swivel bather.
181. PB also considered the assessment included contradictory information, for example, in ‘Transfers’  the Registrant has recorded Service User 29 was able to demonstrate ‘sit to stand transfers from bed to chair, bath transfer and bed’ independently without the need for equipment to assist her. However, later the Registrant records observing Service User 29 holding onto a perching stool and holding onto a grab rail to get in and out of the bath. Also, the Assessment records that Service User 29 has ‘no problems with undressing and dressing’ but then states she has a ‘poor range of movement which affects ability to reach for personal care’.
182. In her written representations, the Registrant said she had recorded Service User 29 being in a choir because that indicated that she was able to leave the house and socialise. This in turn meant that the service user was motivated and more inclined to participate in a bathing assessment. The reference to making quilts demonstrated that Service User 29 had fine hand-eye co-ordination and dexterity and so should have no problem with motor skills, such as turning on taps. The Registrant said she did not understand what PB meant by a lack of clinical information.
183. The Panel had sight of the assessment and accepted PB’s evidence that it lacked detail because it did not focus sufficiently on the service user’s difficulties in respect of bathing. On this basis the Panel found Particular 23 proved. It was not persuaded, however, that the assessment was contradictory since the Registrant was simply recording what the service user had told her and what she herself had observed. The Panel did not consider references to choirs and quilt making to be irrelevant, and understood and accepted the Registrant’s explanation for including them.


Decision on Statutory Grounds
184. The Panel next considered whether the facts found proved amounted to misconduct. In so doing it took into account all the evidence and the submissions made. The Panel accepted the advice of the Legal Assessor.
Particular 24 - Misconduct not made out
185. When deciding whether the facts found proved amounted to either misconduct or a lack of competence the Panel took into account the following:
• the Registrant was on a Performance Improvement Plan for a number of years and, by 2016, two and half years after she started with the Council, she remained on an intensive Supervision Schedule of meeting supervisors up to twice a week;
• continuing issues were being identified with her clinical reasoning, in addition to her recording of assessments, notwithstanding the intensive support and reasonable adjustments put in place in light of her dyslexia;
• in accordance with the expert evidence, it was possible that the Registrant’s dyslexia had a part to play in some of the issues identified, but the adjustments put in place to support her were reasonable  and she could have been expected to perform competently as a result;
• the observation made by KI, and echoed by the Registrant, that the supervision and document checking structure imposed by CC on her would have contributed to the delay in some of the tasks she was required to complete.
186. The facts found proved in this case concerned:
• a lack of clinical reasoning in assessments;
• making contradictory statements in assessments;
• failing to adequately assess service users’ needs;
• recommending equipment that was not suitable;
• a failure to conduct reviews;
• a failure to make records;
• failing to send documents, or the correct documents, when required to do so;
• acting outside the scope of her practice.
187. The Panel considered the Registrant to be in breach of the following parts of the 2012 Standards of conduct, performance and ethics applicable to all HCPC Registrants:
 1 You must act in the best interests of your patients, clients and    users.
 7 You must communicate properly and effectively with service     users and other practitioners.
 10 You must keep accurate patient, client and user records. 
188. The Panel considered the Registrant to be in breach of the following parts of the 2016 Standards of conduct, performance and ethics applicable to all HCPC Registrants:
 1 Promote and protect the interests of service users and carers.
 2 Communicate appropriately and effectively.
 6 Manage risk.
 10 Keep records of your work.
189. The Panel found there to be breaches of the following parts of the 2013 Standards of proficiency for Occupational Therapists in England:
 Registrant occupational therapists must:
 1 be able to practise safely and effectively within their scope of    practice;
 2 be able to practise within the legal and ethical boundaries of     their profession, in particular 2.1 - understand the need to    act in the best interests of service users at all times;
 4 be able to practise as an autonomous professional, exercising    their own professional judgement;
 10 be able to maintain records appropriately;
 14 be able to draw on appropriate knowledge and skills to inform    practice;
 15 understand the need to establish and maintain a safe practice    environment, in particular 15.1 - understand the need to    maintain the safety of both service users and those    involved in their care.
190. In relation to Particular 2(b) the Panel determined that, whether considered alone or in conjunction with other findings of fact, this Particular did not amount to either misconduct or a lack of competence. The Panel accepted the plausible explanation given by the Registrant for not wanting to have Service User 2 present. She had observed behaviour by Service User 2 which concerned her and she decided she did not want him present when assessing the property whilst the family were in residence. The Panel considered this to be a reasonable course of action in the circumstances.
191. In relation to Particulars 15 and 19, the Panel accepted the evidence of KI, as echoed by the Registrant, that the supervision and document checking regime imposed upon the Registrant by CC contributed to the delay. In both cases the delay had not been great and furthermore, in relation to Particular 19, the Panel noted that the Registrant had not had training in the specific form of adaptation required. For these reasons, the Panel did not consider these Particulars amounted to either misconduct or a lack of competence, whether considered in isolation or in conjunction with the other failures identified in this case.
192. The Panel noted that Ms Sheridan, on behalf of the HCPC, characterised this as a lack of competence rather than misconduct case. Over a significant period of time and involving multiple service users, the Registrant, inter alia, failed to provide adequate clinical reasoning for her recommendations, failed to keep proper records, failed to conduct reviews, failed to send documents in a timely manner and recommended unsuitable equipment. However, the failures identified were not such that, individually or collectively, fellow members of the profession would find them to be deplorable. The Panel agreed with Ms Sheridan that this was more a case of lack of competence than misconduct, although it was at the high end of cases of lack of competence. Accordingly, the Panel did not find that the facts found proved amounted to misconduct.

 


Particular 25 - Lack of Competence made out
193. The Panel noted the Legal Assessor’s advice that a lack of competence implies a standard of professional performance which is unacceptably low and which has been demonstrated by reference to a fair sample of the registrant’s work. A lack of competence refers to a lack of knowledge, skill or judgment of such a nature that the registrant is unfit to practise safely and effectively in any field in which the registrant claims to be qualified or seeks to practise.
194. The Registrant had difficulties during her probation with the Council. She disclosed that she had dyslexia and an ATW assessment was carried out. As a result of that assessment reasonable adjustments were put in place to support the Registrant in her practice. The expert witness, AE, gave evidence that individuals with dyslexia, who are provided with the appropriate support, training and equipment, are expected to achieve as competently as their peers.
195. Notwithstanding that support, training and equipment, the same issues with the Registrant’s practice repeatedly occurred over the following 18 months or so. As a consequence, the Registrant continued to be closely monitored and supervised. KI said that seven different people carried out that role and found the Registrant to be making the same fundamental errors. Over the three years the Registrant was employed by the Council, it was clear to the Panel that a lot of time and effort had been invested in trying to support her so that she could perform safely as an autonomous Occupational Therapist. However, she let her colleagues down by failing to come up to standard and as a consequence others, who had tried very hard to help her. At no stage did the Registrant appear to appreciate the impact her lack of competence was having on other members of staff, who had to deal with her case load.
196. In her written representations, the Registrant indicated that she believed that her various supervisors had effectively conspired with KI to get rid of her, but the Panel did not find that to be borne out by the evidence. Indeed, many of the witnesses spoke favourably and empathetically about the Registrant. They understood how she might feel the close supervision was onerous or punitive and could see that she was really endeavouring to get things right. However, their concern was to ensure she practised safely and until she could demonstrate her ability to do that, she could not be left unsupervised.
197. The Panel was satisfied that the Registrant’s performance between 2013 and 2016 was unacceptably low and that this had been demonstrated with reference to a fair sample of her work (22 different service users). The facts found proved demonstrated that the Registrant had a lack of knowledge, skill and judgement of such a nature that she is unfit to practise safely and effectively as an autonomous Occupational Therapist. Accordingly, the Panel found that the facts found proved amounted to a lack of competence.

Impairment
198. Having found the statutory ground of lack of competence to be well founded, the Panel went on to consider whether the Registrant’s current fitness to practise was impaired as a result of that lack of competence. In doing so it took into account the submissions made by Ms Sheridan and accepted the advice of the Legal Assessor.
199. The Panel had been advised by the Legal Assessor that an important factor when considering current impairment is whether the conduct which led to the allegations is remediable, that it has been remedied and that it is highly unlikely to be repeated. The Panel was of the view that all the conduct identified in this case is capable of remedy. However, there was no evidence before the Panel that any of it had in fact been remedied and in light of the repeated similar failures over a considerable period of time, during which reasonable adjustments had been made and intense supervision provided, there was every reason to believe the conduct would be repeated.
200. Another significant factor at the impairment stage is the insight shown by the Registrant. It is fair to say that in her written representations, the Registrant had demonstrated some insight in that she accepted she failed to keep certain records and that she had made some errors. However, she disputed the majority of the allegations and, in particular, those that alleged her clinical reasoning was inadequate. In the absence of insight into those failings the Panel could not be assured she would not repeat the same errors if allowed to practise without restriction. Furthermore, the Registrant clearly believes that Cornwall Council, and specific individuals within Adult Social Services, are largely to blame for the failures alleged against her and the Panel considered this to be indicative of a registrant with limited insight.
201. The Panel was not provided with any information from the Registrant about what work she has been doing since leaving the Council in December 2016 and any training or courses she has attended aimed at the identified deficiencies in her practice. The Registrant had not provided a properly reflective statement or indicated what strategies she might put in place to avoid a repetition of her previous failings.
202. In all the circumstances, the Panel considered there to be a risk that the Registrant could in the future put service users at unwarranted risk of harm. Furthermore, if she were to repeat the same errors in the future, that would be liable to bring the profession into disrepute and would be in breach of one of the fundamental tenets of the profession, namely the need to act in the best interests of service users at all times. The Panel therefore found the Registrant’s fitness to practise to be currently impaired on public protection grounds.
203. The Panel went on to consider whether this was the type of case that required a finding of impairment on public interest grounds in order to maintain public confidence in the profession and the Regulator. The Panel was satisfied that a fully informed member of the public, who was aware of all the background to this case, would have their confidence in the profession and the Regulator undermined if a finding of impairment were not made. This is particularly so given the extensive nature of the failings and the extended period over which the Registrant continued to make the same fundamental and basic errors in her practice as an Occupational Therapist.
204. The Panel therefore determined that the Registrant’s fitness to practise is currently impaired both on public protection and public interest grounds and that the allegation of impairment is well founded.

Sanction
205. In reaching its decision on sanction, the Panel took into account the submissions made by Ms Sheridan, together with all the written evidence and all matters of personal mitigation. The Panel also referred to the guidance issued by the Council in its Indicative Sanctions Policy (“ISP”). The Panel had in mind that the purpose of sanctions was not to punish the Registrant, but to protect the public, maintain public confidence in the profession and maintain proper standards of conduct and performance. The Panel was also cognisant of the need to ensure that any sanction is proportionate. The Panel accepted the advice of the Legal Assessor.
206. The Panel considered the aggravating factors in this case to be: the duration of the failures, spanning almost three years and encompassing fundamental areas of practice; the number of service users affected; a lack of insight into many of the failings; no significant or sustained performance improvement, despite two and a half years of intensive supervision, the deficiencies remained, notwithstanding appropriate reasonable adjustments; no evidence of remediation.
207. The Panel considered the following mitigating factors; no previous disciplinary matters before the HCPC; some, albeit limited, insight with admissions to some of the failures; some remorse; comprehensive written submissions relating to the matters alleged; the witnesses spoke favourably about some areas of her practice, particularly her relationship with service users, and were empathetic to the difficulties she faced whilst subject to intense supervision.
208. In light of the risks identified by the Panel and the Registrant’s inability to perform as an autonomous Occupational Therapist, the Panel did not consider this was an appropriate case to take no further action or make a Caution Order, since neither would protect the public from the risks identified by the Panel or reflect the seriousness of the persistent wide-ranging competency failures identified. The Panel was also of the view that public confidence in the profession, and the HCPC as its regulator, would be undermined if such failures were dealt with by taking no further action or a caution.
209. The Panel next considered whether to place conditions on the Registrant’s registration. The ISP states that before imposing conditions a Panel should be satisfied that:
• the issues which the conditions seek to address are capable of correction;
• there is no persistent or general failure which would prevent the registrant from doing so;
• appropriate, realistic and verifiable conditions can be formulated;
• the registrant can be expected to comply with them; and
• a reviewing Panel will be able to determine whether those conditions have or are being met.

210. The Panel also noted from the ISP that conditions will rarely be effective unless the Registrant is genuinely committed to resolving the issues they seek to address and can be trusted to make a determined effort to do so. The Panel considered that ordinarily the failures in this case, which are all clinical failures, could be addressed by conditions. However, the Registrant had not attended the hearing and in her written representations she had only dealt with the allegations and her view of the Council and her supervisors. She had not shown insight into the majority of the matters alleged (and now found proved), and the impact of her conduct on service users, her colleagues, the profession and the public.
211. The Panel had no information about what the Registrant had been doing in the two years since she was dismissed from Cornwall Council, or what her intentions are for the future. The Panel could not know, therefore, whether the Registrant is committed to resolving the issues the conditions would seek to address or could be trusted to make a determined effort to do so. Furthermore, in light of the fact that the Registrant had effectively been under a form of conditions (intense supervision) for the last two years or so, it was not immediately apparent what further conditions could be formulated to provide the necessary degree of protection for the public. The Panel therefore concluded that a Conditions of Practice Order would not be workable in this case, at least not without further input from the Registrant.
212. The Panel thus considered whether to make a Suspension Order. The ISP states that, “Suspension should be considered where the Panel considers that a caution or conditions of practice would provide insufficient public protection.” The Panel has already concluded that a caution or conditions would not provide sufficient public protection. The proven allegations are of a serious nature and, in light of the limited insight and complete lack of remediation, there was a real concern that the behaviour would be repeated.
213. An Occupational Therapist is expected to work autonomously and must be trusted to carry out the most fundamental and basic aspects of that role, as identified in paragraph 186 above. A failure to do so puts vulnerable service users at risk. The Panel has found that the Registrant failed, over many years, to act in the best interests of her service users and concluded that there continues to be a risk that she would do so in the future if allowed to practise without restriction. The Panel noted the comments of some of the witnesses:
· RG said “Normal supervision would be once a month with most other Band 5’s. Karen Bennetts had twice a week at times…We were trying not to allocate her the more difficult Band 5 cases…We weren’t confident she was demonstrating adequate clinical reasoning - we hadn’t seen sufficient clinical reasoning to prove she was safe for the more challenging cases. We didn’t consider she was safe without a lot of guidance.”
· AW said that by 2016 she had no faith the Registrant could practise autonomously, “By the time I supervised her in 2016 she’d had the software - and by that stage the issue was clinical reasoning and still making the same mistakes after 3 years…We couldn’t continue with that level of supervision.”
· PB said, “We put so much support in…we went over and above for Karen. All supervision sessions were documented so she could refer back, we frequently adjusted the caseload, she worked from home a lot to the extent that we asked her to come in a bit more to access that support.”
· KI said, “It wasn’t about grammatical mistakes. She couldn’t pull together information about occupational performance and what outcomes this might have - it had nothing to do with spelling.’
214. What was apparent from the evidence is that even with all of the reasonable adjustments being put in place, combined with intensive supervision, the Registrant was unable to demonstrate a standard of work whereby Cornwall were satisfied she could practise independently and safely.
215. The Panel concluded that, in light of the seriousness of the lack of competence, the limited insight and the complete lack of remediation (or evidence of a willingness to remediate), there is a real risk that the behaviour would be repeated.  The only appropriate sanction, therefore, in this case was to make a Suspension Order. The Panel took into account the impact this would have upon the Registrant, but concluded that the need to protect the public outweighed her interests and that no other sanction would adequately protect the public.
216. The Panel did not consider a Striking-off Order, since this sanction is not an option in a lack of competence case, at this stage.
217. The Panel therefore directed the Registrar to suspend the Registrant’s registration for a period of 12 months. This would allow the Registrant sufficient time to decide what she wishes to do with her career, to demonstrate reflection and remediation and to demonstrate to a review Panel that an alternative Order may be appropriate. This Order will be reviewed shortly before its expiry and a reviewing Panel may be assisted by:
• the Registrant’s attendance at the review;
• evidence of continuing professional development (CPD), including relevant training, online or otherwise, reading and/or shadowing;
• a reflective statement; demonstrating how any CPD undertaken relates to the findings made at this hearing and demonstrating insight into those findings;
• relevant up-to-date testimonials from any paid, or unpaid, employment in any area of activity.

Interim Order

218. The Panel heard submissions from Ms Sheridan on the need for an Interim Order to cover the period during which an appeal may be made and, if one is made, whilst that appeal is in progress. The Registrant was not present and therefore the Panel had first to decide whether to proceed to consider the Interim Order application in the absence of the Registrant. The Panel heard and accepted the advice of the Legal Assessor.
219. The Panel decided that it was appropriate to consider the Interim Order application in the absence of the Registrant. In reaching this conclusion the Panel took into account the contents of the Notice of Hearing sent to the Registrant on 24 August 2018, where it is stated under the heading “Interim Orders”, “Please note that if the Panel finds the case against you is well founded and imposes a sanction which moves, suspends or restricts your right to practise, it may also impose an interim order on you (under Article 31 of the Health and Social Work Professions Order 2001). An interim order suspends or restricts a registrant’s right to practise with immediate effect.” The Panel was satisfied that this meant that the Registrant was on notice that this was a possible outcome at this hearing.
220. The Panel remained satisfied that the Registrant had voluntarily waived her right to be present at the hearing by her clear indication that she would not be attending. The Panel could see no reason to adjourn the hearing in order to allow the Registrant to attend on a later date because there was no indication that she would attend on any other occasion. The Panel took into account the fact that it had identified there to be a continuing risk to the public if the Registrant were allowed to practise without restriction and decided it would not be unfair to consider the Interim Order application in the absence of the Registrant.
221. The Panel has found that the Registrant lacked competence in the following respects:
• a lack of clinical reasoning in assessments;
• making contradictory statements in assessments;
• failing to adequately assess service users’ needs;
• recommending equipment that was not suitable;
• a failure to conduct reviews;
• a failure to make records;
• failing to send documents, or the correct documents, when required to do so;
• acting outside the scope of her practice.
222. The Panel had concluded that the Registrant represents a continuing risk to the public because there remains a concern that she would repeat the behaviour in the absence of any evidence to the contrary. The Panel therefore concluded that an Interim Order was necessary to protect the public from the risks it had identified during the 28 day appeal period, or the time taken to conduct any appeal, in the event that one is made.
223. The Panel is also of the view that, given the nature and seriousness of the lack of competence in this case, public confidence in the regulatory process would be undermined if the Registrant were allowed to remain in practice on an unrestricted basis. The Panel therefore determined that an Interim Order is otherwise in the public interest.
224. The Panel first considered whether a Conditions of Practice Order would be sufficient. However, for the same reasons as dealt with at the sanction stage, the Panel concluded that conditions would not be appropriate. This was because there was no indication that the Registrant would engage with any conditions, even if conditions could be formulated that would provide the necessary degree of the protection for the public.
225. The Panel therefore decided to make an Interim Suspension Order under Article 31(2) of the Health and Social Work Professions Order 2001, the same being necessary to protect members of the public and being otherwise in the public interest. This order will expire: (if no appeal is made against the Panel’s decision and Order) upon the expiry of the period during which such an appeal could be made; (if an appeal is made against the Panel’s decision and Order) the final determination of that appeal, subject to a maximum period of 18 months.
226. That concludes this hearing for today.

Order

That the Registrar is directed to suspend the registration of Miss Karen Bennetts for a period of 12 months from the date this order comes into effect.

Notes

No notes available

Hearing History

History of Hearings for Miss Karen Bennetts

Date Panel Hearing type Outcomes / Status
26/11/2018 Conduct and Competence Committee Final Hearing Suspended