Three letters that PM’s dread to hear, but is it all that bad?

One thing that is for sure is that no two visits are ever the same. Your visit depends on the inspection team on the day. Contrary to what people may think CQC does not “tell” the inspection team what to do or what to look for. They have a list of guides/suggested questions, but they are expected to use their knowledge and expertise to think on their feet to react to what they find. The background of the Inspector has a lot to do with where they focus, an inspector who is an ex nurse for example will take a different approach to an inspector who is an ex tax inspector; they are drawn to the area they feel comfortable in.  Because CQC inspections are not simply a tick box exercise you will have practices on one area being marked as outstanding when in other areas it’s just considered to be “the norm”.

What powers do CQC have? 
CQC has the right to enter your practice whenever they want. Normal visits will be announced, usually with two weeks’ notice, but if they are responding to concerns that have been raised, they can visit without notice. CQC “can” close you down but you would need to be doing something massively dangerous to warrant an immediate closure notice.

As an ex Practice Manager Specialist Advisor for CQC practice visits (before they decided a PM presence wasn’t necessary) we were always told to go in with a mind that the practice was good, to look for evidence of outstanding but to react to any indication or concern that things might not be quite right. If the inspection team get a hint of something being not quite right, they will focus on it and dig either for proof that it actually is ok or evidence that will support any notification of regulation breach.

CQC cannot tell you how to run your practice. They work to a list of “key lines of enquiries” or KLOE’s.  These look at whether you are safe, effective, caring, well led and responsive.  You can read more about these here:
https://www.cqc.org.uk/sites/default/files/20171020-adult-social-care-kloes-prompts-and-characteristics-final.pdf

The CQC works to the regulations in the Health and Social Care Act 2008.
https://www.legislation.gov.uk/ukpga/2008/14/contents#:~:text=%EE%80%80Health%20and%20Social%20Care%20Act%202008%EE%80%81%201%20The,of%20the%20Health%20Professions%20Adjudicator.%20More%20items…%20

The inspection team may try to tell you that you “must” do something a particular way, but this is not within their remit. The only time they can tell you that you “must” do something is when there is a breach of one of the regulations in the Act, but even then they can’t tell you “how” to meet the regulation only that you “must” take action to make sure you do.  The CQC MythBusters page is a great place to look for confirmation if you think the inspection team are telling you something that sounds wrong
https://www.cqc.org.uk/guidance-providers/gps/nigels-surgery-full-list-tips-mythbusters-latest-update

Don’t be afraid to look things up and then challenge what the inspection team is telling you.

The CQC are not all bad and a visit should not be feared, although when we get that call, we all spend the next two weeks running round like a lunatic. All practices now will have had at least one visit, so you will either be at least “good”, or you will know what actions you have to take. As long as you maintain what you are doing there is no reason that you won’t maintain a good rating at a subsequent visit.

Top tops: play the game, make sure your best receptionist is on the desk when they arrive, make sure the people you “want” them to speak to have free time and those you don’t want them to speak to – well just keep them busy. Use the presentation to tell the inspection team what you do well. Don’t be afraid to steer them to look at things you want them to see.  Do your groundwork – keep policies reviewed and up to date so its not a mad dash when you get your visit notification., but whatever you put in your policy make sure you are actually doing it!!

CQC will always want to triangulate evidence so as well as looking at your policy they will want to check with staff that they are following it and have evidence of it being done as well. CQC work on outcomes so just because you think you deliver a wonderful, innovative service if it doesn’t improve patient outcomes CQC are unlikely to see it as wonderful as you do so always relate things back to how it has improved patients’ health or better still get the patients to come in and talk to the inspection team.

Doncaster LMC has a good document on their website which you can use as a guide to what you can use as evidence against the different KLOEs.

If you are on social media, then Facebook has a good practice manager group in which people post lots of documents and hints and tips and don’t forget to ask your local PM’s for help.

Leave a Comment