This article has been provided and sponsored by Quality Compliance Systems
Author: Tracy Green, head of primary care at Quality Compliance Systems
Much has been written about the Care Quality Commission’s (CQC) decision to temporarily postpone routine inspections until the autumn.
In the interim period, however, practice managers will be aware that the CQC is still closely monitoring the sector – not in person, but by telephone – using the Emergency Support Framework (ESF).
The ESF, launched on 18 May, has a dual purpose. It has been specifically designed to assess whether GP practices are continuing to provide safe and effective services, while its secondary function is to help the CQC understand the daily issues that GP practices face during the pandemic.
What is less clear is when the CQC will be actually be conducting the telephone interviews. As a former practice manager, I don’t know of anyone who has yet received a call from the CQC. It appears that very few practice managers have been contacted.
However, with the CQC inspection team likely to be conducting calls well into the autumn, one certainty is that every practice manager in the UK must be prepared and ready to receive a call.
The big questions, then, are what will the CQC’s interview entail, and how do you best prepare for it?
There is much uncertainty surrounding the ESF, and from my role at Head of Primary Care at Quality Compliance Systems – which creates up-to-date policies and procedures for GP practices – we’ve responded by producing a comprehensive guide.
This article also provides practice managers with further insight as how to interpret each area.
The first point to make is that the telephone call will cover four central themes (Safe care and treatment; Staffing arrangements; Protection from abuse; Assurance processes).
Each theme will be broken down into a series of key questions. In total, across the four key themes, there are 15 questions that practice managers need to answer. You can find the full list of questions in QCS’s Emergency Support Framework Guidance, but before providing guidance on each area, there are some preparatory steps that you should first consider.
- Read the guidance on the CQC website
- Talk to staff and patients, so you can provide a rounded picture that includes a list of challenges your practice has faced during the pandemic
- Update your Business Continuity plan if it does not illustrate or reflect how you have been operating during the pandemic
- Ensure all audits and planning continue. Actively use the evidence gathered to support the points you make in the interview. You can use our reflection toolkit to gather and display evidence.
Now, let’s look at each individual theme.
1. Safe care and treatment
This question is focused on infection prevention and control, and whether related risks have been effectively assessed and managed. Therefore, the CQC will not only want to know if your practice has the correct PPE for every eventuality, but it has enough of it. They are likely to ask about the infection prevention and control procedures that were enacted around the safe operation of ‘Covid hot rooms’, about donning and doffing PPE protocol, and whether staff continue to have access to the most up-to-date guidance in this area. But it’s not just about staff adopting best practice; practices will be expected to provide clear evidence that the guidance is made available to patients and visitors, too.
While this information will provide the CQC with a clearer picture as to whether the practice environment is suitable to contain an outbreak, the inspector may also ask for additional information on this point. Firstly, practice managers should fully risk assess the building to ensure that it is Covid-secure.
With GP practices located in a wide range of different buildings, there are two key points to consider. First, whatever type of building the practice operates from, you should evidence the risk assessment of your premises including how staff and patients safely access and exit the practice. Second, after fully risk assessing the building, practice managers should have created cleaning, handwashing and hygiene procedures, and erected signs which also highlight social distancing rules in the surgery.
Third, the extent to which a practice is utilising Accessible Systems is another key area that the CQC will be keen to explore. In a time of Covid, accessibility is about ensuring that clinicians and administration staff have the ability, the training and resources to use video conferencing when face-to-face contact isn’t possible. That said, even in height of a pandemic, there will always be occasions when face-to-face consultations need to take place. The CQC will want to see that those most in need can visit the surgery.
Finally, whether your practice uses digital compliance system or a paper-based one, the practice manager needs to be able to demonstrate that your risk management system can assess risks, whether they are Covid or non-Covid-related.
2. Staffing arrangements
This question seeks to verify, not just whether your GP practice has enough staff, but whether those staff can provide safe, person-centred care and treatment to patients: can staff adequately service the needs of patients with physical and learning disabilities? In answering this question, practice managers need to be able to evidence that they have achieved the right balance of non-clinical and clinical staff, and, with the spectre of Covid still looming, to minimise risk. That means having a clear understanding of which staff can work from home and still do their job effectively, and which staff are needed at the surgery.
The second question is about contingency. The CQC wants to be sure that practices have made robust plans to address a staff shortfall in an emergency. Therefore, the CQC is looking for evidence that practices have adopted a collaborative outlook and have pro-actively formed contingency plans with other practices in their local area or worked with their Primary Care Network.
Most importantly, the CQC will want to know what that strategy looks like at a more granular level. For example, how many other practices is the practice partnering with during the crisis? Does each practice have adequate resources to send staff to other practices, when required, or patients for that matter? What is the plan if much of the team are affected by Covid and how will the practice continue to deliver safe care?
There is also an expectation during the pandemic that some roles could change. The CQC will want to know that each person, who has been assigned a slightly different role, has not only received adequate training, but that the training and supervision surrounding it, is being logged, monitored and assessed.
Finally, regarding recruitment during the pandemic, the CQC will be keen to establish that where necessary – DBS checks are being carried out in a timely manner, and all other checks are completed safely.
You may also refer to our Covid secure returning to work policy.
3. Protection from abuse
The key questions in this theme are focused on whether people using the service are being safeguarded from abuse, neglect and discrimination during the pandemic.
While this is an area that all GP practices take exceptionally seriously, it could be – for safety reasons – that the Coronavirus epidemic has meant that only essential staff are on-site. The CQC, therefore, want to see that the practice has the right staff in the practice at the right time to cope with every scenario.
If, for example, a vulnerable patient comes to the surgery, the expectation would be that, regardless of the pandemic, the person is chaperoned by a trained and experienced member of staff to their appointment. From an organisational perspective, that could mean two people being donned in full PPE (should it be required).
In relation to managing safeguarding incidents or concerns, while I don’t wish to dwell too much on the subject, I would advise that practices log all incidents and concerns and keep an up-to-date record. It might be that the pandemic throws up some unique scenarios in these challenging times.
Many of our clients have told us that the QCS Reflection Toolkit has provided them with a quick and effective of achieving their goals in this respect. You can download the toolkit if you’re a QCS customer.
4. Assurance processes, monitoring and risk management
The last theme checks that systems you have in place suitably protect the health, safety and wellbeing of staff. The questions are very much focused on the wellbeing of staff. Have you given the staff the correct equipment, training and support to be able to do their job safely, efficiently and effectively at home? If staff are using their own laptops or company ones, has all anti-virus software been updated? Is the video conferencing technology they are using safe from hackers? Most importantly, have you evidenced this and logged it?
For staff working in the surgery, there are other challenges. With hot-desking banned, do all the desk in the practice have dividers? Are they positioned at least a metre apart, and is there a steady supply of anti-bacterial and anti-viral wipes in the surgery for staff and patients? Finally, if not all of the surgery is being utilised during the pandemic, there may areas that are cordoned off. If taps are not being used in these areas, the CQC will want to see that health and safety procedures such as legionella checks are still being carried out.
For more information on health and safety guidance and returning to the practice, see QCS’s Covid secure document.
GP: Free Emergency Support Framework Guidance