As a locum CQC advisor, it is part of my job to help APMS, GMS and PMS practices get ready for an inspection at short notice, or to help them out of special measures and achieve a good rating – so it’s fair to say I’m used to the process. But after a practice manager stepped down at another practice, I recently found myself stepping in at the last minute to support an inspection – and the CQC’s new regulatory approach was not what I was expecting.
We know that how inspections are carried out has changed because of the Covid-19 pandemic and the need to keep CQC staff safe, but what really threw me was that this inspection was going to be done over three days, instead of one. Normally, you do all the hard work and it’s all over in one day, with some good, not so good, or terrible feedback afterwards.
The three-day inspection for the practice was broken down as follows:
No site visit, but a four-hour interview with the practice manager via Microsoft Teams. Further interviews were undertaken with different team members and those who have core roles, such as the assistant practice manager, secretary, data quality leads, practice nurse, health care assistant, regular long-term locum GP and ANP. This was all done via Teams or over the phone. If the inspector did not get time to speak to all the staff they had arranged times with, then they rescheduled for an alternative day.
A site visit from a clinical pharmacist, which took around five hours.
The clinical pharmacist looked at the DMARDS and controlled drugs monitoring, and whether the INR is being monitored correctly.
Other questions asked included: are shared care agreements in place with hospitals? Have medications reviews been done?
The pharmacist looked at appointments over the last month and selected various patients – so I would suggest it’s best practice to ensure that all medication reviews are up-to-date for those patients who have had consultations in the last 30 days.
The pharmacist also checked that medication has been issued correctly. For example – a script being requested four times should not be approved by four different clinicians. EMIS and SystmOne will alert you to this, but Vision does not. So my advice if you are a Vision user is to please take a closer look at all of the prescriptions issued in the last month, and also see what is about to be issued on the day of the site visit.
Finally, the clinical pharmacist looked at our workflow methods, and how documents are being filed. If you have 200 documents waiting to be filed, I would advise that you make sure to only have five discharge summaries left on the day of inspection!
The lead inspector and CQC GP did a site visit, which lasted approximately six hours.
The lead inspector expected the practice manager to have a document outlining the practice’s responses to comments made on NHS Choices, and plans going forward.
It’s best to have all personnel files ready for inspection and to remember that the more thorough these are, the better. I would suggest including CVs, application forms, interview notes and scoring, job offer letter, two references, DBS, appraisals, competency-based induction, two forms of identification, right to work in the UK, immunisations, certificates of qualifications, indemnity, performer’s list, offer of the NHS Pension, completed training, holiday leave, sickness, and confidentiality forms.
Take time making these folders – the better the quality, the better the impression.
The inspector also wanted to see minutes of meetings and how they link to our significant event logs. Do the minutes make sense or are they jumbled up? It was important to make sure that the inspector can follow these in a logical order.
If you have TeamNet I would recommend using this for significant events, as it follows a good process, and has all the review dates. The CQC GP sat with one of the clinicians and looked at the significant events, asking why certain levels are low, such as immunisations or cervical screening.
Be ready to show that you have evidence to demonstrate how you are making improvements – they will also ask why certain QOF targets have not been met.
The GP also looked around the practice to ensure that oxygen, defib, and the emergency trolley were all up to standard.
‘A Goliath task’
Questionnaires were sent to almost all of the staff, and the CQC then wanted to interview them. These interviews were to confirm information that you as the practice manager have sent, so they will cross-check your policies of recruitment.
Do the staff know who is the safeguarding lead? Are they up to date with any recent MHRA and drug alerts? Was there a competency check at induction?
As there will be many people the CQC wants to interview, it is best to keep a log of what staff members can speak and at what times – and e-mail this information to the lead inspector. It is also best to prep your staff on two recent MHRA alerts.
Another major change is in what the CQC asks you to do prior to their visit. Previously it was statement of purpose, infection control, staff details, and few other things. Now this has become a Goliath task – they wanted us to provide a great number of documents and policies in advance, so that we could demonstrate how our practice is safe, caring, responsive, effective and well-led.
Safeguarding policies will need to be up-to-date and we were asked to show a log of the safeguarding referrals in the last 12 months, that these have been audited, and what lessons the practice has learnt from why certain referrals were rejected.
Risk assessments will also need to have been carried out for all rooms and corridors – I’d really recommend using a web portal where you can record assessments. I use one that comes with a great template, which can be altered to suit your specifications, and can be emailed as a PDF to the inspector.
My top tips
- Talk about social prescribing, lone working and how you develop your staff CPD needs.
- Ensure the rooms are spotless, decluttered and shelves are empty.
- Show that you have worked on the results of clinical and non-clinical audits, not simply say you have carried out risk assessments or audits.
- Make sure policies all get reviewed on one day – 5 November is usually a good day for doing this.
Best of luck!
Aditya Kohli is a practice business manager and supports practices to prepare for CQC inspections in a locum capacity.