This article relates to the CQC key questions: Is your practice caring? and Is your practice responsive to people's needs?
The CQC has had questions from practices and inspectors about whether practices are expected to provide access to translation services (written communication) or interpreters (verbal communications) for people whose first language is not English.
In particular there have been questions about whether printed information should be available in multiple languages.
It is important to make the distinction between:
- people whose first language is not English, and
- those who have a disability which makes communicating in spoken and/or written English difficult or impossible.
In the Equality Act 2010 there are additional requirements to make reasonable adjustments for disabled people. This means that interpreting for deaf people and providing written information in alternative formats such as Large Print on request are likely to be legal requirements for GP practices, though 'reasonability' is decided on the facts of each case.
There is no reasonable adjustments requirement in relation to interpreting and translation on the grounds of race or nationality. Whilst is does not specifically mention people whose first language is not English, the GMC’s Good Medical Practice 2013 states that ‘you should make sure that arrangements are made, wherever possible, to meet patients’ language and communication needs’.
What will the CQC look at during inspections?
When looking at how caring GP practices are during inspections, one of our Key Lines of Enquiry is: ‘Are people who use services and those close to them involved as partners in their care?’
Inspectors consider whether staff recognise when people who use services and those close to them need additional support to help them understand or be involved in their care and treatment, and enable them to access this. This could include providing language interpreters where appropriate or providing printed information in different languages.
However this does not necessarily mean that, for example, we would expect all GP practices to have information leaflets available in multiple languages.
The key point is that services should be responsive to the needs of the population they serve and this will vary from practice to practice. A practice should be aware of the needs of the people on their patient list, including their language requirements.
So if, for example, they serve a population with a large number of people whose first language is not English they should plan services appropriately; considering how they provide information about the services offered by the practice and how these people will be able to be involved in their care. This might mean making printed information available in different languages and/or ensuring that people who use services and those close to them are able to access interpretation services.
It is worth noting that NHS England is currently looking at arrangements inherited from PCTs with a view to providing further guidance in this area. We will update this mythbuster as and when further information is available.
NHS England is also developing an Accessible Information Standard which will require people's information or communication needs to assessed and met. The standard will include the provision of information in accessible formats and communication support for people with impairments. It will apply to NHS services, doctors and dentists providing NHS services and publically funded adult social care services.
- Professor Nigel Sparrow is senior national GP advisor and responsible officer at the CQC
More CQC resources
- View the full CQC Essentials series on Medeconomics
- CQC's recommended reading to help practices meet regulations and prepare for an inspection