CQC specialist adviser Tracy Green advises practices on how to approach regulatory compliance and be prepared for a CQC inspection at any time
Being prepared for a CQC review at any time sounds like a huge task and isn’t easy to accomplish. However, as many things, it very much depends on your starting point.
As many of you know, the Care Quality Commission (CQC) is the regulator for health and care in England. It has three main functions:
In terms of monitoring ratings, there are four possible outcomes: Outstanding; Good; Requires improvement and Inadequate.
Where services are rated good or outstanding, further inspections used to take place up to once every five years unless there was other information that was of concern to the regulator. The monitoring methods have changed considerably since 2019.
In early 2021, a pilot began where remote assessments took place. This was rolled out later in 2021 and is ongoing to date. Where this takes place, an additional note is placed onto the CQC website for the provider. This can be found in the reports section of the CQC website and states the date that the remote review took place, that they found no cause for concern, and did not need to carry out a full inspection. If there is no note for your practice, it may be that your inspector is seeking further assurances or may be planning a full inspection.
The great news is that around 95% of GP practices in England are rated either Good or Outstanding based on the current available data.
Where do I start?
You may be very new to general practice or have decades of experience. Either way, it can be a daunting prospect when you receive the call to say that an inspection is planned in the near future – usually in just a couple of weeks! Thankfully, unannounced inspections are very rare in general practice.
The first thing I recommend you do is understand the Key Lines of Enquiries (KLOEs) or standards expected of you as a service provider. They are:
- Safe: are staff and users protected from abuse and avoidable harm?
- Effective: is the practice’s care, treatment and support achieving good outcomes, and helping to maintain quality of life and based on the best available evidence.
- Caring: Do staff Involve and treat users with compassion, kindness, dignity, and respect?
- Responsive: are services organised so that they meet users’ needs?
- Well-led: is the leadership, management, and governance of the organisation making sure it is providing high-quality care that’s based around Individual needs, encouraging learning and innovation, and promoting an open and fair culture.
As an example, within the ‘Safe’ domain you will need to demonstrate that recent recruitment processes have followed your policy and are in line with safe recruitment principles to safeguard children and vulnerable adults. A top tip for this is to review your policy and make sure it is still appropriate. If not, change it, but with version control, and share with others responsible for hiring at your practice to check the changes are clear and easily understood. Then create a simple tick list, to make it easier to follow the process for each new starter.
This will form evidence you can then show to the CQC team either prior to, or at the visit.
Which KLOE to focus on first?
It may seem obvious, but I suggest focussing on ‘Well-Led’ and ‘Safe’ as priorities, with ‘Responsive’ next.
If you can confidently provide evidence that these domains have been reviewed, it is likely that this excellent work will be relevant for the ‘Caring’ and ‘Effective’ standards too. So as not to waste your hard work, you will need to remember to map the relevant evidence across all the areas to make sure there aren’t gaps.
The Well-Led KLOE is made up of eight domains and focusses heavily on leadership; governance; engagement of staff, patients, and stakeholders; delivery of high quality and sustainable care; risk management and underpinning all of this, a culture of continuous improvement. A robust annual plan for quality improvement is an effective way to schedule audits throughout the year, including clinical, medicines management and non-clinical audits, such as premises.
The CQC will look for outcomes as a result of audits. A popular model you may wish to use is the Plan, Do Study, Act (PSDA) model which will complement second audit cycles. Significant event analysis and complaint reviews will form part of this, so consider what you already do then check you have documented outcomes and available evidence.
When looking at the Safe standard, consider what your expectations are of any health and social care setting. Strong governance foundations are essential, as are processes, and being open and learning from mistakes. Do get your pharmacist or GP medicines management lead involved to ensure that accurate standard operating procedures are in place and also being followed and reviewed when needed.
Induction and training also fall into the Safe standard, as does safeguarding. Break the work down into bite-sized chunks, allocating work streams to others.
Consider these top tips for being prepared for inspections
- Involve the team, ideally allocating lead areas
- Carry out an honest baseline assessment
- Create an action plan. RAG (Red-Amber-Green) rating, also known as traffic light coding, is a good way to show areas that are on track or that still carry risks
- Arrange regular reviews to keep on track. If you are creating a new plan and processes to work towards a Good rating, weekly progress and accountability meetings are recommended
- Segment dedicated time for compliance activity
- Monitor and celebrate progress
- Seek external support if required
- Be aware of, and use, available data in the public domain such as public health data like Fingertips and SHAPE Place Atlas, and patient feedback, such as from GP Patient Survey and NHS Choices.
- Work with a buddy practice, your PCN or wider area to share workload
- Don’t panic!
What has changed?
I would be so bold to say that last year’s outstanding is the equivalent of today’s good.
Features such as working at scale and digital innovation are expected as routine now, as is patient involvement, and aspects such as being veteran, dementia, and carer-friendly. There are some outstanding features that CQC teams highlight, which you can find out more about from recently published reports on the CQC website.
A rating of Outstanding, in my opinion, is becoming more difficult to achieve especially in the current climate when business as usual is incredibly demanding. It’s not impossible, however, as there are 362 providers registered to deliver GP services currently rated Outstanding. So, why not you?
What else do I need to know?
The CQC is developing a new approach to regulation. Until they introduce this new assessment framework they will continue with their current methods to monitor, assess, and rate providers. They will use a single assessment framework with ratings and the five key questions (KLOEs) will remain central to its approach. So, it will continue to use:
- Five key questions (safe, effective, caring, responsive and well-led)
- The four-point ratings scale (outstanding, good, requires improvement and inadequate).
Tracy Green has been a primary care manager for 14 years, a CQC specialist adviser since 2014 and supports practices, PCNs and the wider teams as a healthcare business consultant and coach