The Care Quality Commission (CQC) regulates against the Health and Social Care Act 2008 (Regulated Activities) Regulations 2010 and the Care Quality Commission (Registration) Regulations 2009, which outline the essential standards of quality and safety that care services must provide. Details of which you can find in the CQC’s Guidance about compliance: Essential standards of quality and safety
How is this reflected in general practice? What must practice managers and staff do to ensure practice compliance with the standards and how to ensure that you are prepared for an announced inspection by the CQC?
A keen focus
In order to be able to meet the standards, you must know the standards and what the inspection focus will be. The main priority for the CQC is assessing the experiences that people have when they receive care and the impact that care has – on patient health and wellbeing – and this is judged against the regulations.
Inspectors want to know how your practice is operating and will turn up announced. During the inspection they’ll speak with patients and observe the workings of the practice; their findings checked by looking at records or speaking with practice staff.
There are three types of inspection that they will carry out: a responsive inspection – carried out at any time in response to identified concerns; a themed inspection – which looks at specific issues or concerns that have been raised at a national level; and a scheduled inspection – which is planned by CQC in advance and carried out at any time. In their guidance, the inspectorate says that they will usually only focus on one ‘essential standard’ from each of the five key chapter headings as identified in their annual guidance about compliance.
Preparing for inspection
‘Registered persons’ are responsible for monitoring compliance with the ‘essential standards’ in a practice and will need to be able to demonstrate how the quality of service and monitored. The CQC provide a useful compliance tool available on their website, but often practices will have their own systems in place. The CQC provides the following example: ‘Your system may include how you assure yourself of the quality of your service by reviewing and acting on people’s feedback through comment cards and surveys, or audits of your service’s performance.’
The CQC is continually assessing and reviewing the information that they hold and receive on practices they regulate. For example, information on your last inspection report, notifications, concerns, complaints and safeguarding alerts, contract monitoring reports, as well as information from stakeholders including members of the public and your local Healthwatch. This information decides which of the essential standards to inspect in a practice. It also decides if an inspector should be accompanied, by an ‘expert by experience’ or professional advisor, to gather and assess the practice.
When the inspector comes to town
On arrival at the practice an inspector will present their identification and ask to speak with the registered person – if they’re not available they will seek out the senior person in charge. At this point you will also be informed which kind of inspection it is – scheduled, themed or responsive – and which essential standards will be inspected. You will usually be given time to prepare on the inspector’s arrival.
During the inspection, observation of practice interactions and care provisions will be cross-checked against care records, plans and other information. The inspector is looking for instances where regulations are not being met but will also note in their report evidence that standards are being met.
You can expect inspectors to:
- observe patients and patient care;
- speak with patients and staff of all levels;
- check that staff understand their role within patient outcomes and what to do if they have concerns;
- in some cases, carry out ‘pathway tracking’ – following a person on their journey through the practice, noting their views on it;
- ask to see specific areas of your service – for example, how you store medicine;
- ask to see information, such as training records;
- ask how you record patient feedback and to see it;
- look for records that are detailed and accurate.
Inspectors should be sensitive when observing care – ensuring that they do not breech a patient’s privacy. Nor will they read policy or procedure documents in excessive detail – unless to substantiate other evidence.
At the end of your inspection
Additional information may be required to ensure that judgements are comprehensive and fair. This may be communicated to you at the end of the inspections, or you will later be contacted. This must be provided within 48 hours. Feedback will usually be provided at the end of the visit.
Sit back relax, wait for your report
The CQC has a judgement framework that all inspections are marked against; it looks at whether, or not, your practice meets regulations and standards and helps the CQC make its judgement – which will be fully evidence-based.
The report itself will set out the CQC’s finding and judgements. Should it be deemed that the practice was not meeting one or more standards, this will be explained in full – describing the impact it is having on patients and the action that will be pursued. You will be able to request a rating review.
The best advice – in life – is to be prepared and this is no different. There are great resources available that provide clear guidelines, as well as checklists and steps to help prepare for your inspection. You’ll find some below.