This article relates to the CQC key question: Is your practice well-led?
One of the five key questions we look at on our inspections is how well-led GP practices are.
The characteristics of a ‘well-led’ practice and the key lines of enquiry we use on our inspections are published in our provider handbook appendices.
To make a judgement about how well-led GP practices are, our inspection teams look specifically at the governance arrangements within a GP practice. Clinical governance is an important aspect of a practice’s governance arrangements but is not covered here: see effective clinical governance arrangements in GP practices.
What is governance?
Governance is a systematic approach to maintaining and improving the quality of patient care and service delivery.
It should be given a high priority by all healthcare providers. Governance should be led by senior members of the practice who understand their responsibilities and are accountable for practice performance. All staff members should be involved.
Governance and CQC inspections
We ask whether a GP practice’s governance arrangements ensure that responsibilities are clear and that quality, performance and risks are identified, understood and managed.
As part of this we consider:
- Is there an effective governance framework to support the delivery of the strategy and good quality care?
For example, we expect to see structures, processes and systems of accountability to be clearly set out, understood and effective. These would include the governance and management of partnerships, joint working arrangements and shared services.
- Are staff clear about their roles and do they understand what they are accountable for?
- Is there an holistic and comprehensive understanding of performance, which integrates the views of people with safety and quality information?
For example, we would expect the information used in reporting, performance management and delivering quality care to be accurate, valid, reliable, timely and relevant. We would expect to see some of the following examples of information gathered and included: unexpected deaths, significant events, patient feedback and complaints, prescribing performance, QOF and enhanced service performance data, clinical and non-clinical audit findings, risk assessments, policy reviews, business plan (please note, this is not a definitive list).
- Are there comprehensive assurance systems and performance measures, which are reported and monitored, and is action taken to improve performance?
We expect to see effective systems and processes to assess and continually monitor the service which reflects the changing needs of people who use it. An effective system should be overseen by senior members of the practice and involve all staff.
- Is there a systematic programme of clinical and internal audit, which is used to monitor quality and systems to identify where action should be taken?
Regular audits of the service provided should be used to assess, monitor and improve its quality and safety. These should, where possible, include the experiences of people who use the service. See Clinical audits
- Are there robust arrangements for identifying, recording and managing risks, issues and mitigating actions?
GP practices should have processes and information to manage current and future risks. Risks recorded should align with what people say is ‘on their worry list’. Systems and processes should enable practices to identify where quality and/or safety are being compromised and respond appropriately without delay.
When we inspect we will talk to staff at all levels to get their views on the governance in the practice. For example, asking them what their role is in the governance framework and how decisions are made and communicated to all staff members. We will also consider evidence from practice meetings, such as minutes, to judge how effectively the governance arrangements are functioning.
If we find that a GP practice does not have effective governance processes we will consider whether they are meeting the regulations which set out the fundamental standards of care.
- Regulation 17: good governance
- Regulations for service providers and managers
- Guidance for providers on meeting the regulations (PDF)
Professor Nigel Sparrow is senior national GP advisor and responsible officer at the CQC