Many GPs were alarmed by the recent Care Quality Commission (‘CQC’) statistics published in Pulse confirming that, when applying for CQC registration, 20% of all GP practices declared non-compliance with one of the 16 essential standards of quality and safety.
It’s important to remember that almost every GP practice which applied for CQC registration prior to 1 April was successfully registered despite declared areas of non-compliance. Non-compliance does not automatically result in a CQC ‘failure’ or the closure of your practice.
In fact, legislation governing CQC registration specifically allows providers to self-declare non-compliance along with an action plan setting out how they will become compliant within a reasonable timescale.
I set out below some simple answers to the questions most commonly raised by my GP clients.
If you add a new service to your practice or extend the premises you must re-apply to the CQC.
False. You would not need to re-apply to CQC for registration in these circumstances.
However, the Care Quality Commission (Registration) Regulations 2009 require all registered services to notify CQC about certain changes, events and incidents affecting their services or the people who use them. This is done by completing a form, not through a fresh application for CQC registration. Events about which you must notify CQC include changes to the kind of services you provide, abuse or allegations of abuse carried out during the provision of care or any change in the membership of your partnership.
The CQC will ask you to remove carpets, soft furnishings and skirting boards, regardless of how easy it is to disinfect them.
False. The CQC uses a judgement framework to assess whether a service complies with the 16 essential standards of quality and safety, one of which is cleanliness and infection control. There is no blanket ban on carpets or skirting boards (although some PCTs did mistakenly direct GPs that they needed to remove these items to be CQC compliant). The issue which CQC will assess is whether the GP practice complies with the cleanliness and infection control standard, with or without carpets in situ.
One of the new standards will measure how ‘caring’ GPs are towards patients.
False – this year. The Care Quality Commission (‘CQC’) assesses whether services meet 16 essential standards of quality and safety. Caring is not one of the specific essential standards.
However, CQC has recently announced its strategy for 2013 – 2016. This includes changing what they look at when they inspect services. The new aim is to tackle five simple questions about any service, which are:
– Are they safe?
– Are they effective?
– Are they caring?
– Are they well-led?
– Are they responsive to people’s needs?
These changes will come into effect in NHS hospitals and mental health trusts first, but will be extended and adapted to other sectors, including GPs, during 2014 and 2015.
The CQC also inspect GPs’ fitness to practise during inspections.
False. Doctors’ fitness to practise is regulated by the General Medical Council (‘The GMC’), not CQC. CQC exists to regulate health care and adult social care services in England, as well as protecting the interests of people whose rights are restricted under the Mental Health Act.
However, whilst CQC’s purpose is not to inspect GPs’ fitness to practise, CQC will look at whether any service’s staff, including its GPs, are safe and effective. CQC makes clear that, where it identifies serious concerns about a healthcare professional’s fitness to practise, its ‘Chief Inspectors will make sure that concerns…are brought to the attention of other regulators and partners in the system’. Earlier this year, The GMC and CQC entered into a Memorandum of Understanding which provides that CQC will inform The GMC of three things:
– any concerns and relevant information about a doctor which may call into question his or her fitness to practise;
– any concerns and relevant information about a healthcare organisation or a part of that organisation which may call into question its suitability as a GMC Approved Practice Setting or learning environment for medical students or doctors in training;
– any concerns and relevant information about a healthcare organisation which may call into question the robustness of its systems of medical appraisal and clinical governance.
You can be reported to the GMC if you fail to meet CQC standards.
True. As I said before, incidences of non-compliance with CQC’s essential standards can be minor, moderate or serious.
However, it is only intended that CQC will share information with the GMC where, as part of its inspection of an overall service, CQC identifies concerns about an individual doctor which are serious enough to indicate the doctor’s fitness to practise may be impaired.
Andrea James is head of healthcare regulatory at George Davies Solicitors LLP, a former in-house solicitor to the General Medical Council and specialises in advising doctors.