Every English practice will be subject to routine inspections by the CQC after registration starts from 1 April, and inspections will then take place every two years – or more frequently, if there are particular issues or problems identified.
The CQC has promised that 48 hours notice will normally be given of the inspection date, although that is hardly long enough to make much of a difference. If they feel that it may be necessary, the CQC also has the right to make unannounced inspections as well at any time. So it will pay dividends always to be prepared for the inspector to call.
The following tips should help you prepare for CQC inspections, and each one explains a suggested ‘action plan’ of a practical activity you can do for tips you find helpful.
1 Prepare the evidence to demonstrate that that you are meeting standards
Don’t try and sweep difficult areas under the carpet. Think through what information you already have (e.g. QOF performance statistics, policies, training records, copies of staff qualifications) to make sure that you have evidence to demonstrate how the practice is meeting each of the essential standards.
Action plan: Develop up-to-date action plans in place for any areas of difficulty – even if it will take some little time to achieve the desired improvements.
2 Anticipate the issues that the CQC inspector is likely to be concentrating on
These can be expected to include aspects such as infection control, safeguarding and CRB/DBS checks, patient engagement, staff recruitment, premises, record keeping systems, confidentiality, equipment and patient safety in the practice.
Action plan: Get some local intelligence from neighbouring practices about the topics which cropped up during their inspection.
3 Check all your staff understand the role of the CQC
Train your staff about the CQC, so that they understand what it is and how it works. Don’t forget that the inspector may ask to talk to anyone working in the practice. In particular, fully brief the Partners. They are all legally responsible for their CQC obligations, so it is essential that know about the CQC’s essential standards and what the practice is doing to meet them.
Action plan: Schedule a whole-practice meeting to inform staff about the CQC, check staff know where to find all policies and whether they know what steps you’re planning to take to meet Essential Standards.
4 Don’t overthink it
Don’t lay out the red carpet – the CQC will want to see the practice ‘as it is’. And don’t focus just on your written policies and procedures – the inspector will be mainly looking for what happens in practice, whether systems work, whether staff are trained, etc.
Action plan: Arrange a mock inspection – and help relieve anxiety by having a partnership-level meeting to discuss its results. This means you can be frank, and decide jointly on your priorities for the future.
5 Think through the implications of your CQC inspection report being publicly available
Agree who can handle any media enquiries, prepare a press statement to respond to any problems highlighted and use your practice website to explain what is planned to respond to the inspection, for example. If you have a chance to comment on the draft inspection report (e.g. to make any corrections to error of fact), make sure that you do this within the timescale allowed.
Action plan: See if the LMC will offer to advise you on any problems that might arise here.
6 Assess the risks that your services present to patients, as well as the risk of not meeting the CQC standards
Remember, that’s what the inspection is all about. It is not just an opportunity for some external bureaucrats to try and catch you out! Inspectors will be looking at aspects such as:
– breaches of Health and Safety regulations
– how the telephone is answered
– information for patients
– how staff speak to people
– whether full explanations about care are given
– whether chaperones are offered when appropriate.
Action plan: Get ideas for improvements from all your staff, and include these as part of next year’s appraisal for all staff.
7 Anticipate that the inspector may wish to see a sample of patient records
For example, to check on their format and completeness. The general rule is that the name of the patient should be anonymised, although the CQC do have powers to see individual patient records for which generally prior written consent will need to have been given by the patient.
Action plan: Inform patients this may happen, and reassure them that information will be kept confidential.
8 Check your paperwork is up to date
You should check paperwork is up to date, especially your ‘statement of purpose’ – this needs to changed with 28 days of any changes that take place in the practice (such as new services, changes of staff, or partner retirements) Make sure that your staff know where they can access key information such as telephone numbers of the local Child Protection service for referrals, up-to-date copies of the practice’s policies and procedures.
Action plan: Make full use of the practice intranet, as well as having hard-copies of all such information readily available in just one place.
9 Tell your patients they might be interviewed by an inspector
The CQC inspector will wish to talk to patients so alert your patients about the role of CQC, how it works, and the fact inspections are held periodically.
Action plan: Mention the CQC in your practice leaflet and website if possible.
10 Deal with your anxiety before the inspector arrives
If you treat the CQC with respect, this is likely to be reciprocated. Don’t be defensive: the inspection can offer an opportunity for a fresh look at how the practice is providing services for its patients. If you can demonstrate that you are a learning organisation which is already looking to improve? – you’ll be 90% of the way to a successful outcome of your CQC inspection. And if they arrive on an inconvenient day? – that’s likely to be tough-luck.
Action plan: Much of your work is done as a practice team – so prepare for the CQC as a team-effort. If you need to let off steam about the CQC, find a third-party to listen rather than taking it out on the inspector.
Richard Banyard is the director of CQCassist Ltd, a specialist support service for CQC registration