CQC Inspection. Is your practice prepared?

CQC has recently published a guide for GP practices to help prepare for CQC inspections that will take place after 1st April 2013.The guidance clarified certain aspects of the inspection and what will happen and will help practices to prepare.

Experience of Patients

The guidance confirms that they are particularly interested in the experience of the services users – they will check the information that they receive from the patients through a variety of sources in the practices.  This emphasis means that practices will need to make their patients aware of the possibility of a visit and certainly inform patients who will be attending appointments of a CQC inspection day.

Patients should be encouraged to look at the CQC website and to make comments via the “Please tell us about your experience” section.  Any feedback from your own patient participation group or via the national patient experience survey will be useful for the inspectors to review.

The CQC Inspection Visit

The guidance confirms that CQC will consider all the information they have about a practice including complaints or comments on NHS choices before they visit and that they may use this information to select which of the 16 Essential Standards of Quality and Safety they might want to inspect.

They have also announced that if they have any specific issues that might require “specialist knowledge or expertise” they may bring with them an “expert by experience” to help gather information.

A practice will get at least 48 hours notice of a routine CQC Inspection (remember that Responsive visits may be unannounced).  No information will need to be sent to them beforehand but they may ask to see things on the day so it is important that either the Registered Manager or a Nominated Individual will be available to help with this.

The CQC inspectors will announce themselves and show appropriate identification – there will not be any element of “mystery shopping” and the CQC inspector will tell you which of the essential standards they want to focus on. If possible, they would like a suitable space to work from and where they can talk to patients, or the team about the services. CQC Inspections are not likely to last for more than a day.

The CQC inspectors recognise that not all team members will have the same knowledge and at people will not be asked questions about aspects of service that they are not involved in. The CQC inspectors will not be expecting to sit in on consultations but will want to track things through the practice looking for the links between things as shown in the example below:

a)      You have a policy on chaperoning
b)      They can see how frequently you review it and who is involved in this
c)       Everyone knows where the policy is kept
d)      Those who perform the role of chaperone know what they policy includes
e)      They have received appropriate training or guidance and there are records of this
f)       There is information available for patients in appropriate places and formats
g)      If asked - Patients know how to request a chaperone
h)      The offer and use of a chaperone is read coded in the patient notes

CQC have indicated in the guidance:

“We won’t normally spend a great deal of time reading policy or procedure documents, unless we need to look at them to substantiate other evidence”

However all your policies and documents must be kept up to date and be available at the CQC inspection. If CC ask for information that you don’t have available at the time, you will normally be given 48 hours in which to produce it.

CQC Inspection Reporting

CQC inspectors will usually meet with the Registered Manager before they leave to clarify any further action or requirements and then they will process their report.  The following example shows an example of a CQC inspection visit report from a dental practice where they assessed TWO outcomes at the inspection visit.

They spoke to SEVEN patients or service users on the day the CQC inspection. The report explains the judgement's they make and  these reports will be available on the CQC website once completed with your practice’s overall assessment .

This following link gives an example of where CQC inspectors are not satisfied that the standards are being met and the action they require a practice to take.

The report from a CQC inspection visit will normally be sent by email to the Registered Manager or Nominated Individual within 10 days of the inspection and the practice will have 10 days in which to comment on it before the report is published on the practice’s CQC profile page.

CQC Compliance Actions

Post the CQC inspection if they find that you are not fully compliant with a standard you will be required to complete an action plan showing what you intend to do – CQC will send you a template for this action plan which will need to be submitted to them within a strict timescale of between 1 and 4 weeks.  This will be for non serious or first time problems that they encounter. If a problem is more serious in terms of its impact upon patients or has occurred more than once during the CQC inspection they can take enforcement action. This action can be

Enforcement action can be under either:

  • Civil enforcement: to protect people from harm
  • Criminal law: to hold a registered provider or manager to account for causing harm or for breaking the law.

Under civil enforcement CQC can:

  • Issue a warning notice
  • Impose or change a condition of registration
  • Suspend registration
  • Cancel registration

Where people are at immediate risk of significant harm, CQC can use their ‘urgent’ powers, which means that in some cases they can take immediate action.

Under criminal law CQC can:

  • Issue a warning notice
  • Issue a fixed penalty notice
  • Offer a caution
  • Prosecute

CQC can also prosecute providers who are not registered when they should be.

If you are issued with compliance actions you should normally contact CQC to let them know and they will then verify this within 3 months.

Practice Actions

What do managers need to do now:

  • Consider the sufficiency of their evidence and the  patients’ entire journey through the practice prior to the CQC inspection.
  • Make sure that all team members know what a CQC inspection will entail and how to respond to questions.
  • Keep all your records up to date including training and maintenance records and all your risk assessments. These will be looked over during the CQC inspection.
  • Consider how you will communicate with patients

Thornfields@fpm are the leading training organisation for the primary care sector and can provide training for managers or the whole practice team about CQC and the CQC inspection process. See our course lists for the two course agendas for details or contact us.

We are also offering limited places on an Manchester. For more details check out our blog post on The FPM CQC Roadshow


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