Locum CQC advisor Aditya Kohli discusses what practice managers need to consider when preparing their practice’s significant events log for inspection.
As a practice business manager and locum CQC advisor, I have been through a lot of inspections. But during the Covid-19 pandemic there have been many changes. The inspections are becoming more focused on the evidence that you provide. One of my very good friends is an inspector, and he gave me some useful tips, which I think would be good for all practice managers to consider.
One key focus of CQC inspections is significant events. CQC will ask for a log of your significant events prior to the inspection. This has not changed from before, but how you display your significant events in a log is very important. They can no longer just be reported and have a review date of how we learn from them. So, let’s break down what the regulator expect’s a good significant event to look like from start to finish.
Do you have a significant event lead?
A recent surgery I work with was so dedicated to significant events that they appointed a member of the admin team as ‘significant event lead’. Dr Hussain, who worked at the practice, noted that significant events are not only a learning purpose, but also a reporting process, and a time management strategy. Yes, patient care has to be improved, and things learnt, but were the processes you used up to the highest standard or not?
Together we looked at the practice’s reporting forms, which is very important for recording significant events. The usual components should be there, including the nature of the event, people involved, and key dates. But practices should also consider whether they need to input a clinical code, which the event links back to? Maybe the nature of the event needs a clinical code in the patient’s records, for example. If a wrong diagnosis has been made, or a wrong dosage of medication issued, have we coded that, and coded the revision?
Your significant event will also only be as good as the report it is based on. The report should be as detailed as possible, and if a Riddor form needs to be filled out, then mention this. My advice is to include the following components in your reporting form:
A) Does MHRA need to be informed YES/NO
B) Does the CCG need to be informed YES/NO
C) Does the Patient need to be informed YES/NO.
I would also suggest including categories of severity too.
Learning from significant events
The CQC will want to see some sort of clinical significant events, so GPs can demonstrate how they are learning from what has occurred. This can also be reflected in their appraisals/revalidation. The GMC requires doctors to declare and reflect on those significant events in which they have been personally named or involved, and in which a patient or patients could have or did come to harm. This means that all significant events that meet the GMC threshold of harm must be included in the significant events at your appraisal, but you do not need to provide your reflection on them.
On the day of inspection, I would also suggest trying to demonstrate a ‘good’ significant event, which went well and had a positive outcome, not just the bad ones.
How should practice managers use the information from significant event forms?
Firstly, did you interview the people involved? Have you completed an investigation stage as you would in a disciplinary meeting? These notes are critical so we can evaluate how to proceed. The more information we have, the better the outcome.
We need to be neutral when investigating, and always bear in mind that we do not live in a blame society. Mistakes happen to all of us but being open and honest is the way to move forward. Once actions have been decided, we need to share these with the whole team, not just certain colleagues.
Any action required after a significant event should be addressed straight away, especially if it is of critical importance. Following this, an audit needs to be carried after two weeks, then at three months, and then six months. These audits should demonstrate an upward positive trend. If this is not happening, then perhaps a new strategy should be thought out, in order to improve safety and patient care.
If the CQC sees reoccurring patterns in significant events, this will not look good, and they will deem the practice ‘inadequate’ for safety, as you will not have demonstrated that there is a culture of learning, or of putting staff and patient care forefront. So, work well and hard on significant events with clear revision dates and proper tabular evidence to show you have carried out actions and that this has led to better practice.
If you would like more help please contact me.