PRACTICE MATTERS  CQC INSPECTIONS


Ian Cooper of Capsticks solicitors offers advice on how to prepare for a CQC inspection


GETTING THE RIGHT RESULT G


OING through a new-style CQC inspection can be a stressful and protracted experience, as those


practices who have been inspected will know. It can take up to three months after the inspection to receive the draft report along with the proposed ratings. I am frequently contacted at this stage by practices who are of the view that the draft inspection report and ratings do not accurately reflect the standard of care they provide. What then follows is a process of challenge to the draft report which is finally published with an amended narrative and, very often, improved ratings. However, the key question here is what


can practices do to ensure that the draft report is “right” first time? There are a number of steps you can take to achieve this goal. Understanding and complying with the


CQC’s ‘fundamental standards’ is essential and goes hand-in-hand with having sound governance and assurance arrangements to monitor ongoing compliance and act on any issues arising. This should form part of the everyday business of any practice.


UNDERSTANDING THE BENCHMARK In addition to understanding the legal requirements which make up the fundamental standards, practices need to keep up-to-date with how these standards are being interpreted and relevant inspection trends. Primary care organisations have secured the highest percentage of ‘good’ ratings among CQC-registered providers but there is no room for complacency. It is important for practices to keep up-to-date with published CQC reports and guidance to understand, for example, what makes the difference between ‘requires improvement’ and ‘good’. By reflecting on these trends and benchmarks, practices will be able to ensure that they avoid common pitfalls and stay on the right side of ‘good’ in regard to all five of the key questions considered in CQC inspections: is your practice safe, effective, caring, responsive and well-led?


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For example, the table at the foot of the


page contains a sample of the types of issues arising within the ‘safe’ domain. It is equally important to keep an eye on


what ‘outstanding’ looks like. So in the ‘safe’ domain, evidence of “an open safety culture” and “comprehensive systems to keep patients safe from harm” will score highly with the CQC who will want to see significant events reviewed on a regular basis internally and externally (by bringing external stakeholders and multidisciplinary teams into the review meetings) before awarding the highest rating available. This exercise can be carried out across all


five domains. For example, issues arising in the ‘well-led’ domain might look like this:


KEY QUESTION: WELL-LED Vision, culture and communication issues: • Lack of succession plans in place for key staff, such as the practice manager or lead receptionist


• Lack of a clear vision and strategy • Failure to involve key staff such as the practice nurse in plans to introduce new clinics


•


No clear leadership structure and no whole-practice meetings


• Not all staff had received regular performance reviews


Engagement and patient involvement: • No adequate patient participation in the practice and no mechanism to obtain feedback from patients


• No systems to use complaints to improve the service delivered.


Governance: • Absence of any recorded governance meetings


•


No risk log or register to collate and mitigate relevant risk issues


KEY QUESTION ‘Inadequate’ or ‘requires improvement’ examples SAFE


Lack of consistent systems for reporting, recording and monitoring incidents; staff not clear on threshold for reporting incidents


Lack of robust safeguarding processes and gaps in staff training and awareness in this area (especially for reception and administrative staff and locums)


Shortcomings in recruitment procedures and pre-employment checks (including DBS checks)


No clear evidence of patients receiving a verbal and written apology in line with the Duty of Candour requirements.


AUTUMN 2016  ISSUE 15


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