CQC practice manager adviser Josiane Wadey suggests ways to prepare for when the inspectors come calling.
When I learned we would be having inspections from the Care Quality Commission (CQC), I wanted to understand what would be expected of us and share my learning through our practice management network – so I applied for a post as CQC practice manager adviser. Two years on, I have done a number of inspections on my days off and have learned a lot from them.
I have been able to see where practices need to tighten their systems to satisfy key lines of enquiries (KLOE) and have also been able to improve systems in my own practice.
For example, I implemented a central staff database. On a simple Excel spreadsheet (which is password protected) I have every member of staff listed, their address, date of birth, start date, hours they work, qualifications, when their Nursing and Midwifery Council (NMC) registration is due, whether they are chaperone trained, disclosure and barring service (DBS) information, emergency contact details, last appraisal date, indemnity provider, when their next revalidation is due etc. I knew CQC would want these details, and I had them, but in different places. It was helpful to put it all in one document to send to the CQC and it helps me keep on top of everything now.
This is directly relevant to success in the ‘safe and well led’ KLOE, which I have seen some practices struggle with. DBS checks have not been carried out on key staff. Fridges have not been checked. Prescriptions or drugs have not been locked away and significant events have not been discussed. Staff have felt unsupported, have not had regular appraisals or have told the inspection team that they are unable to get to meetings – or that there are no meetings.
My spreadsheet method then enabled us to think about collating all the staff training. So we have an Excel training workbook with a sheet for each individual staff member and also a sheet with an overview of all mandatory training, staff name, date done etc. When training is due, the colour changes to amber and the staff are emailed and reminded.
Being faced with a CQC inspection can be daunting for everyone. My practice was inspected last August and even though I had a good insight into what would be expected and what would happen, it was still a big deal. Our practice was very proud to be rated as outstanding, but this took years of work from the whole team and our patient participation group. We would not have achieved it without them.
Currently only 4% of practices are awarded outstanding and to achieve it is something to celebrate.
These are my top tips for how best to ensure you are ready for when the inspectors come knocking at your door.
1. Be prepared
Practices are given two weeks’ notice, so be prepared as this will fly. Try to be completely on top of staff training, appraisals, infection control audits, health and safety inspections, fire drills etc. Also ensure there are enough clinical audits, so collate these in preparation and ask clinicians to do second cycles of their audits if they have not already done this.
Check out the series on the CQC website Nigel’s Surgery: tips and mythbusters for GP practices.1 The services provider handbook is also helpful reading.2 Your local medical committee (LMC) will also have good tips.
Ensure all your staff files are complete with, for example, contracts, confidentiality statements, recruitment checks, hepatitis B status, photographic identification, indemnity and DBS checks where appropriate, evidence of mandatory training as above. And ensure the following areas are up to date.
– Staff training and development
Does each staff member have a recent appraisal, a current personal development plan and an up-to-date job description? Does everyone know who their safeguarding lead is?
– Policies
Are all your policies up to date? Pay attention to chaperoning, recruitment, fire, health and safety, infection control, medicines management, business continuity plans.
– Fire
Is your log book up to date? Do you have enough trained fire marshals? Have all your staff done fire safety training? Have you done a recent fire drill? Have you had a recent fire risk assessment? Do you check emergency lighting?
– Legionella
Have you had the relevant checks done and are you continuing to test water temperature?
– Infection control
Make sure you have done a recent audit and have an action plan completed. Do you have cleaning checklists?
– Prescription security
This is really important– do you have a record of serial numbers of prescriptions coming in? Are they kept in a secure place at night and during the day?
– Drugs
Are they locked away? Make sure there are no out-of-date drugs in clinicians’ drawers that they use for demonstration. Are the fridges checked daily and recorded?
– Clinical audits
Make sure you have a good number of recent ones and try to ensure second cycles have been carried out.
2. Prepare staff
I felt it was a good idea to drip-feed the preparation over a long period so that staff could retain the information and not feel so stressed.
I devised little quizzes, sent out weekly questions and organised regular lunch-and-learn sessions to go through the questions they might be asked. Some practices I know held evening events with pizza.
Again, if the staff are prepared and know the answers, it will be less worrying for them on the day.
3. Keep everyone calm
Usually on the day, everyone is anxious. I have heard so many staff say ‘I didn’t want to say the wrong thing’ or ‘I freeze when I’m nervous and my mind goes blank’.
At my practice I told each member of staff to think about what they wanted to tell the inspector, what they were particularly proud of that they wanted to share either from a personal or practice perspective.
I tried to make them confident that they knew the answers and if they didn’t, it was okay as long as they could tell the inspector how they would find the answer.
4. Ensure key personnel are available on the day
Try to ensure as many partners are available on the day as possible. Ask your senior partner to help you meet and greet the CQC inspection team. On some inspections I have been involved in, there has been only one partner at the presentation or sometimes none and the entire day has been left to the practice manager. This can create a bad impression of the practice leadership.
Also ensure your inspectors can meet your safeguarding leads, your infection control lead and heads of department.
5. Listen to and involve your patients
Ask your patient participation group to explain to the inspector how they are involved within the practice. This does not mean how much money they’ve raised; the inspectors are more interested in community and education events, what changes patients have suggested that the practice has implemented to make a positive impact.
Keep all your compliments and gather evidence that you take all comments and complaints seriously. Show how you follow them up. You may wish to discuss your complaints as significant events to share the learning and inform your patients you have done this. Show evidence of this on the day via e-mails and videos.
6. Prepare your premises
Try to ensure your premises are clean and de-cluttered and the reception area is tidy. First impressions count. Soap dispensers should be full. Make sure that your clinical waste bins are locked and secure.
7. Take the day seriously
I have seen some practices destroyed by the fallout of a bad inspection result. The partners and staff all feel guilty, blame each other and leave. Sometimes banks get worried when a practice receives an inadequate rating, and call in their loans – leaving partners to re-mortgage their houses to keep their practice going. Don’t let that be your practice. Do everything you can to make a good impression.
On the day, a warm welcome from the reception team, practice manager and partners, together with a prepared presentation and offer of refreshments, goes down very well and can set a positive tone for the whole proceedings.
Try to allocate a secure room for the inspection team all day and put all the information about policies, significant events, complaints, premises, infection control and health and safety audits in that room so that they have everything to hand. It will save you having to search through your office and computer for them while they stand over you.
8. Try not to be defensive on the day
If an inspector mentions something they feel you should be doing, think of it as a learning experience. I know this can be hard, but the inspection teams I have worked with are much more satisfied if a practice holds up their hand and says they will address the issue.
So if you receive criticism, thank the inspectors for raising it and say you will reflect and discuss this with your partners or at your next staff meeting. Try and think of the day as a learning experience.
9. Celebrate success
Hopefully you will get a good result. When you do, ensure you show how much you value your staff and patients and think of ways to celebrate this success.
10. Reflect
What went well? What could you do better? Share your feedback and report with staff and patients and be open and transparent. Together you can tackle the areas you may need to improve on.
References:
1. Nigel’s Surgery: Tips and mythbusters for GP Practices cqc.org.uk/content/nigels-surgery-tips-and-mythbusters-gp-practices-full-list
2. CQC services provider handbook cqc.org.uk/content/gp-practices-and-out-hours-service-providers
