- Posted Wednesday March 17, 2021
Practice Managers, by and large, are used to seeing the world as it is, responding and adapting accordingly – the management of COVID being a prime example.
With changes to work and income streams in COVID, for PCNs and looking at the implications of the 2021/2022 contract, perhaps we can be excused for not looking too closely at The Government’s recently published White Paper or for that matter, the CQC’s own consultation on its revised strategy.
Press headlines, such as they were, which greeted the former, full working title Integration and Innovation: working together to improve health and social care for all or the latter, Consultation on changes for more flexible and responsive regulation, concentrated (wrongly in my view), on how the bureaucratic burden on the NHS is going to be lifted, or slashed, depending which media outlet you subscribe to.
The detail is rather different.
Checking the Fine Print
The White Paper makes little reference to primary care and no overt mention of regulatory control, such as that exercised by the CQC, although in a further document Busting Bureaucracy, the Secretary of State highlights the changes that the CQC has already made to its inspection processes, see below, as an important part his plan to reduce NHS bureaucracy.
As far as the CQC is concerned, it is worth harking back to the announcements it made in October 2020 for the rollout of its Transitional Monitoring Approach (TMA), part of its proposals to ensure that it could fulfill its statutory functions in a “necessary and proportionate way”, given COVID: these revised arrangements took over from the Annual Regulatory Review and now represent the CQC’s new way of managing general practice inspection, essentially what its strategy consultation has announced, although further changes cannot be ruled out.
It is true that for practices previously rated Good or Outstanding, the CQC has ended its process of inspecting on a regular rolling basis – certainly, the commitment that all practices would be reviewed within 5 years no longer applies and is replaced by TMA, however the regulatory structure which underpins the CQC and its system of inspection, based around the Key Lines of Enquiry, remain unchanged and in the CQC’s own words, TMA provides a “strengthened approach to monitoring, based on specific Key Lines of Enquiry, so we can continually monitor risk in a service”.
As with all CQC requirements and guidance, this new approach exists on its website (if you know where to look!) In time, it will become clearer how the CQC will use its resources to ‘continually monitor’ primary care and since this is risk-based, we must assume that foremost in the CQC’s mind is the conclusions it draws from the data which it is holding on you and which it is regularly updating.
The CQC has previously committed to updating their data collection methodology of its Insight Systems, but it will include;
- Previous inspection reports and ratings
- Monitoring information collected through usual data sources.
- CQC Inspectors knowledge of the service
It will also include people's experience of care and the views of NHSE, CCGs, Health Watch will be added to that mix, which will develop a kind of triage alerting the CQC to the fact that a previously good or outstanding practice is, well, under pressure.
CCGs also form views about member practices; significant staff changes, retirements, recruitment problems, mergers, and, being nearer to and more sensitive to patient complaints and performance issues than the CQC, are a valuable source of data and risk which the CQC will consistently use to bolster its TMA.
How Practices can be prepared for change
The proactive practice should start to put itself in the CQC’s shoes by looking at its own current (hard and soft) data, systematically reviewing:
- QoF data
- National Screening programmes
- CCG Enhanced service standards
- Prescribing data
- Other contractually required data
Thus armed, the CQC will prioritise those practices it wishes to see first.
- It “will have a conversation with you either online or by telephone”; this could be a TEAMS meeting on the basis of which the CQC will decide if it needs to take “further regulatory action (such as) an inspection”.
- That conversation will focus around those relevant and specific key lines of enquiry which the CQC will confirm, the identification and mitigation of risks as well as hearing about examples of good practice.
- The need for more information might become apparent and the CQC will identify the additional information needed within 24 hours.
- Based on this, the CQC reviews what its options for further regulatory action are, which could include inspections.
The CQC has already stated that its prime focus, at least for this initial ‘conversation’ will be examining the KLOEs relating to
- Infection Control
- Serious incident monitoring, including managing the deteriorating patient.
- Protecting patients from discrimination
- Safe Staff levels
- Managing patient safety via face to face and remote consultations
- Ensuring clinical records are up to date.
- Ensuring referrals to other providers and managing any backlogs or waiting lists, ensuring all follow-ups are back on schedule.
- Safe use of medicines
- Managing the vulnerable patients in their own homes or care homes
- Ensuring staff competencies are up to date and reflect any changes in service – e.g remote consultations.
- Ensuring patients do not miss regular screenings and vaccination and immunisation programmes.
In addition to these immediate clinical issues, the review will look at ways in which the practice has changed its business and governance following COVID.
On the basis of this quick resume, you might be asking yourself what happened to this slashing of unnecessary bureaucracy? The CQC hasn’t gone away, practices still face scrutiny. The only difference is that the onus is on you to keep your entire systems up to date rather than wait for a quinquennial CQC visitation.
Your plan should not be 'how do I prepare for an inspection?', but rather ‘how do I ensure the CQC doesn’t need to inspect me?’
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