IMCA involvement in accommodation decisions and care reviews
Closing and deregistering services
Closing services
People living in a service due to close may require an IMCA to be instructed for accommodation decisions. The responsible local authority or NHS trust should instruct IMCAs as soon as it becomes clear that a service may be closed, regardless of how long the closure may take. This is to allow early representation by an IMCA who may, based on their understanding of the person's needs and wishes, decide to:
- challenge a proposed closure as not representing the person's best interests
- make representations about the time before closure that the person should move, rather than, for example, assuming they will remain there until just before the closure.
Deregistering services
The Code of Practice says that IMCAs should be instructed where a person may remain living in accommodation which is deregistering as a care home (10.54). When this happens the options that need to be considered are:
- the person continuing to live in the home with it remaining registered
- the person continuing to live in the home when it is unregistered as a care home
- the person moving to other accommodation.
The IMCA will focus on the following implications for the person if the home deregisters:
- changes to how the person's needs will be met
- physical changes to the building – for example, not having an office on site
- who will be responsible for the tenancy as it is possible that the person will be unable to consent to it themselves
- changes to the staffing arrangements
- changes to the person's finances and who will manage these
- changes to the way the service will be inspected and regulated by the Care Quality Commission (CQC).
