CQC plans to complete its first round of inspections and ratings by April 2016 and it's important to be ready for when their inspectors call. Inspection teams will be made up of a CQC trained inspector, with clinical input from GPs, nurses and other professionals. Teams may also include patients who are considered 'experts by experience'. Here we explain what you need to know.
The most significant changes in CQC's new inspection regime are:
Standards and guidance – 12 fundamental standards have replaced the 28 outcomes in 'Essential standards of quality and safety'. How well practices are meeting the fundamental standards will be assessed against five key questions:
- Are they safe?
This includes factors such as whether medicines are managed properly; whether people, such as those in need of safeguarding, are supported; and whether the practice learns from incidents.
- Are they effective?
Checking that patients are given the right diagnosis and treatment and referred properly to specialist services when appropriate.
- Are they caring?
Whether patients are treated with compassion, dignity and respect
- Are they responsive?
How the practice assesses and responds to patient needs including access to appointments and responding to patient feedback and how medical records are stored and shared.
- Are they well led?
Does the practice support staff by providing training and supervision, and does it work effectively with other health and social care services?
Practices will be scrutinised on how they are performing using a range of information sources such as patient feedback on NHS Choices, complaints, screening uptake and concerns raised by staff. The data will be used as background for inspectors and to create priority bandings for future inspections.
Practices will be rated outstanding, good, needs improvement, or inadequate, using evidence gathered during inspections, through intelligent monitoring and from sources such as Local Area Teams. Ratings are based on how well practices address the five questions above with reference to the service provided to six key patient groups, including vulnerable older people and those with long-term conditions.
The Department of Health wants practices to display ratings in their practice and hope to make this a legal requirement.
How much notice will we have before an inspection?
CQC will give GP practices two weeks’ notice of a Comprehensive Inspection. Out-of-hours GP services will have six to eight weeks’ notice. CQC intends to carry out comprehensive inspections at least once every three years.
However, if CQC is responding to concerns or following up an issue identified during a previous visit, it may carry out an unannounced Focused Inspection. At the start of these visits, CQC says its inspection team will meet with the practice’s senior partner or senior manager on duty and feed back at the end of the inspection if there are any immediate safety concerns.
How should we prepare for an inspection?
Gathering information before an inspection
Before you are inspected you will have been asked for information by the CQC. The documentation typically requested includes summaries of complaints and adverse events, evidence of how you monitor quality of treatment, including patient surveys and staff recruitment and training policies. Provide the information promptly (within five working days, or 10 working days for a GP out-of-hours service). Do your homework – it is likely that questions may be asked that relate to this documentation on the day of the inspection.
CQC’s lead inspector will contact you to introduce themselves and explain the agenda for the day and discuss the practicalities, such as allowing staff time for interviews and ensuring there is an area set aside for inspectors to use.
Before the inspection, you will also be sent comment cards for patients to complete and posters to display in your reception/waiting room which will advertise the inspection and give patients the opportunity to contact CQC directly.
Collect examples of good practice
It makes sense to prepare for the inspectors' initial interview where you will be asked to say what makes your practice outstanding. This includes examples of how you have improved patient outcomes and experience. This is an opportunity to talk about the excellent care and service you provide to patients. Set aside any modesty and be ready to identify and speak about what makes your practice excellent, and makes it stand out from the crowd. The inspection team will be keen to hear about excellence, so prepare thoroughly for this part of the interview.
Be realistic about any particular challenges your practice is facing. It is better to be prepared for questioning and ready to talk about the steps you are taking to address concerns. CQC has said it will judge practices and GP out-of-hours services more harshly if it finds they have not been open about issues of concern and this will affect their rating.
Inspectors will want to speak to GP partners, locums, trainees, practice managers, nurses, healthcare assistants and administrative staff so we advise you to ensure all practice staff are up-to-date with relevant practice protocols and understand what the inspection entails. Consider setting aside a training session where staff are put through mock interviews so that the real thing will not come as too much of a surprise.
It’s also important to know how to access material that might be requested by inspectors as evidence, such as audits, written procedures and patient records (CQC is entitled to review records under section 63(2)(b) of the Health and Social Care Act 2008). The MDU's has guidance on disclosing confidential information to CQC.
CQC has produced a quick guide to help practices understand what to expect from an inspection which covers general preparation, what happens on the day and afterwards. More detailed guidance on preparation and visits can be found in chapters 6 and 7 of CQC’s provider handbook.
What happens after the inspection?
CQC produces a report after each inspection in collaboration with members of the inspection team. The report includes the practice rating (see above), describes the good practice found and highlights concerns and evidence about any breaches of the regulations.
Your comments on the report
The draft report is then sent to the provider who has ten working days to review it. At this stage, submissions can be made about factual inaccuracies and the completeness of the evidence on which the ratings are based. CQC says any factual accuracy comments that are upheld may result in a change to one or more rating. Once finalised, the report is published on the CQC website.
GP practices and out-of-hours services are expected to respond to identified areas of concern and develop an action plan to show how they will address concerns and make the recommended improvements. CQC encourages practices to publish action plans on their own website.
Can we challenge a CQC rating?
In addition to submissions about factual inaccuracies at the draft report stage, practices can also ask for a review of their ratings but only on the grounds that the inspector did not follow the process for awarding them properly (not because they disagree).
In order to request a review, practices must inform CQC of their intentions once the report is published. They will then be sent full instructions and a form to complete. CQC will make clear on its website that the report is under review. The outcome of the review will be sent to the GP practice or GP out-of-hours service and the report and ratings updated if necessary. CQC warns that ratings can go down as well as up following review.
We recommend you contact us if you are considering challenging a CQC report.
What action can the CQC take?
CQC says that where concerns are identified, its response will be proportionate and depend on the potential impact on service-users. This will often be in the form of a recommendation in its report.
CQC is piloting a 'special measures' scheme for practices that are found to be providing inadequate care which it hopes to implement from April 2015. Under the scheme, practices which have been rated as inadequate for one or more of the five key questions or of the six population groups will be given a specified period for re-inspection (no longer than six months). If a practice fails to demonstrate sufficient improvement, CQC can consult with NHS England about placing it into special measures for a maximum of six months. If there is still no improvement after that time, the provider’s registration can be cancelled.
Ultimately, where there has been a breach of regulations (or practices have failed to make improvements), the CQC may use its enforcement powers, including:
- Warning notices telling a provider that they are not complying with a condition of registration or any other legal requirement CQC thinks is relevant.
- Civil law enforcement action may be taken to protect patients from harm by improving the care given to patients, or make it safer. This will normally be by imposing or changing a condition of registration; or suspending or cancelling registration.
- Criminal law proceedings may be used where CQC want to hold a registered person to account for causing harm to patients, or for failing to meet their statutory obligations. Criminal proceedings may result in a fixed penalty notice being served, a caution or prosecution, where a court may convict a registered person resulting in a fine and/or imprisonment.
How can the MDU help?
There are a number of ways the MDU can help. Take a look at our CQC pages.
This guidance was correct at publication 13/01/2015. It is intended as general guidance for members only. If you are a member and need specific advice relating to your own circumstances, please contact one of our advisers.