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What to do if you do not comply with CQC requirements

Donna Hickey explains how practices can put together and implement an action plan for areas where they don't comply with CQC requirements.

From July 2012 NHS GP practices across England will have to set up online accounts to begin the process of registration with the Care Quality Commission (CQC). Practices will then select a 28-day window between September and December 2012 in which to submit their full application to register.

When submitting their final application, GPs and other primary medical service providers will be asked to declare their compliance to the 16 regulations that comply with the Essential Standards of Quality and Safety under part 4 of the Health and Social Care Act.

Action plans

If applicants declare that they are compliant then no action plan box will need to be completed. However, if CQC applicants believe they are not fully compliant, an ‘action plan’ box will then be provided where applicants will need to outline (in 2,000 characters) why, what, when and how they will bring themselves into full compliance with any given regulation.

This means applicants must address:

  • Why they believe they’re not compliant.
  • What they’ll do to become compliant.
  • When they expect to achieve compliance.
  • How they’ll maintain compliance to that particular regulation.

While setting out a full action plan to address these points will be required in due course, there is no need for practices to panic just yet, as all that’s needed at this stage is a mini-action plan designed to address the above four points.

Applicants should remember however that by registering with the CQC, and signing the compliance declaration they are signing a legally binding document. Therefore, if you feel your practice is compliant, you should be ready to provide evidence of how and why your practice is compliant come the time of your inspection.

Be specific

The key point to remember for GPs and other primary medical service providers, is that all action planning – be it either on registration, or post-inspection – is that it needs to be SMART. That is:

  • Specific
  • Measurable
  • Attainable
  • Relevant
  • Time-bound

This means action plans should be specific to the outcome that is being addressed and should also have a system of measurement in place by which providers can measure improvement.

Importantly, any action plan should always be attainable – it should include realistic goals that can be achieved within the plan’s framework, and should equally be relevant to the outcome and the point being addressed.

Finally, the action plan should also be time-bound. This is one of the main areas many CQC registrants have fallen down on previously, and is an essential factor all new applicants should bear in mind. 

In the past, when the likes of dentistry was brought under the umbrella of the CQC, it is fair to say there was a lack of awareness on how to complete action plans, and a lack of guidance on the SMART action plan approach.

With the CQC’s remit now also encompassing GP surgeries and other primary healthcare providers, we have seen a great deal of progress made, with far more information and guidance material now available on the CQC website.

Regular meetings

One important recommendation is for GP practices to have regular team meetings that include discussions surrounding areas of CQC compliance.

By looking at each of the 16 essential standards in turn (one each week), staff will be encouraged to make strides towards bringing the practice in line, while also raising general awareness of important areas for consideration such as patient involvement, infection control, staff training, and record management. This then gives the practice the chance to address important issues now, and so put procedures in place well in advance of compliance declaration and inspection.

Risk assessment

The final thing to remember with CQC registration, is that at its heart it is outcome focussed – it’s not just a checklist. Everything the CQC does and assesses is centred on risk assessment and what is reasonably practicable with the view to protecting patients and improving standards of care.

If you can demonstrate that you are actively aware of the outcomes that affect you and your practice, and that you are proactive in addressing any issues, with a SMART action plan in place, then transition to the CQC should be a smooth and relatively straightforward process.

  • Donna Hickey is head of compliance at dbg, and is responsible for all aspects of compliance for dbg service provision, delivery and content. www.thedbg.co.uk

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