All GP practices in England can expect to receive a visit from the CQC after April 2013. Here are the answers to questions you are likely to have about what a visit entails.
How much notice will we get?
The CQC has said that practices will be given 48-hours’ notice for scheduled inspections.
This is unless the CQC is responding to concerns raised about your compliance with the statutory essential standards or following up on previous compliance concerns – a ‘responsive inspection’ – it will not give any notice.
How should we prepare for the visit?
If you regularly review your compliance with the CQC’s essential standards, there should not be any real need for last minute preparations.
However it is worth taking advantage of the 48-hours’ notice to ensure you give the right impression.
If the practice has an action plan to help it demonstrate compliance with all 28 essential outcomes, you may want to spend a little while reviewing the plan to ensure there are no outstanding items.
It would also be sensible to walk through the practice to ensure that there are no unexpected findings relating to the safety and suitability of the premises (outcome 10) such as non-functioning lighting, unpleasant odours or tripping hazards that might mar an otherwise good inspection.
What will the inspector look for?
Following a pilot of 42 practice inspections carried out earlier in 2012, the CQC concluded that routine inspections would look at a minimum of five outcomes across the essential standard areas.
The CQC has said that its inspectors will spend a lot of their time speaking to patients, their families and carers. They will not spend as much time looking at policies and procedures as they will mainly do this to check what they have been told by patients or staff.
It is advisable to ensure all practice staff are aware what the inspection might entail and where to access the policies and records they need.
We also recommend the practice manager is available on the day to ensure the inspectors have everything they need, to show them around the practice and introduce them to members of the practice team and patients.
The manager should also be ready to produce any documentation requested.
Can the inspector examine patients’ records?
During the pilots the CQC obtained patient consent to inspect medical records, but guidance is awaited on how this will be handled from April 2013 as by then inspectors will a statutory right of access to patients’ records.
Nevertheless, we recommend that you tell patients in advance, for example on your website and in the practice leaflet, that it may be necessary to share their information with inspectors as part of the CQC inspection process.
What happens after the inspection?
In its guide to preparing for an inspection (it has not yet published a version specifically for GPs), the CQC says that around 10 days after the inspection it will send a copy of the draft inspection report to the CQC-registered person at the practice.
The practice then has 10 working days to check the report for factual accuracy and make comments on a template provided. The final report will be sent out shortly after this and will be published on the CQC website.
Following an adverse report, the CQC may also issue a press release so there is also the potential for media interest in the outcome of the inspection. You can contact your medical defence organisation to ask for help preparing a response.
What if we do not comply?
If the CQC inspector judges your practice is non-compliant with the regulations they will decide the appropriate response depending on whether the impact on people using the service is considered minor, moderate or major.
The CQC says the action it takes will be proportionate to the impact that the breach of the regulation has on patients.
In most cases, it will require that the practice addresses failures within a reasonable agreed timeframe, but if this does not happen or the failure is judged to be sufficiently serious, the CQC has powers to begin enforcement action.
What enforcement action can the CQC take?
Under its powers of civil enforcement, the CQC can issue a warning notice; impose or change a condition of registration; or suspend or cancel registration.
The CQC also has powers to take the following action against practices under the criminal law: issuing a warning notice or a fixed penalty notice, offering a caution, or prosecuting.
If that all sounds rather alarming, it is worth pointing out that in our experience of helping dental members with the CQC, it is unusual for a practice to fail to meet an essential standard.
According to the CQC’s first Market Report, 88% of dental practices inspected up to March 2012 met all the essential standards and no enforcement action was taken against any practice.
When can an inspector return?
The CQC has said that routine inspections will take place every two years. However, responsive inspections will be carried out whenever concerns are raised.
- Dr Michael Devlin is head of advisory at the MDU