A CQC inspection can be a daunting experience for any practice. To ensure the visit goes well practices need to set aside some time to prepare for what will actually happen on the day. All practices have now had at least one CQC visit and so most practices will be aware of what they need to do to prepare for a visit.
The information in this series of articles has been pulled together from information on the CQC’s website, BMA guidance on CQC inspection and information on safeguarding that was collated by Londonwide LMCs.
Key lines of enquiry
The CQC released updated key lines of enquiry (KLOEs) and 'prompts' (the questions that feed into the key lines) in November 2017. CQC inspectors use these questions to assess all providers. For each question the CQC has set out what 'outstanding', 'good', 'requires improvement' and 'inadequate' looks like and will use this information to rate your practice.
You can find the KLOEs, along with the characteristics of each rating for each question here (this version highlights what has changed compared with the 2015 version):
These (and in particular the characteristics of each rating) should be the basis of how you prepare for your inspection.
Who needs to be in the practice on inspection day?
Ideally the senior partner, the registered manager (who may be senior partner), the practice manager, the lead nurse and the infection control lead as a minimum.
However, you want as many team members there as possible who can talk through the ethos of the practice what the practice does and how it does it.
Plan the day in advance
Make a timetable for the day. The inspectors ask for a 30-minute presentation to introduce the practice. The BMA has produced guidelines for what to include in this presentation.
The BMA also suggests preparing a welcome pack which has names and roles of key staff, practice leaflet and any other information you think might be useful.
Below is a short summary of some key areas to make sure you have looked at ahead of the inspection
Prepare your staff
The CQC is very keen to talk to staff and patients and to ensure that what the senior partner and practice manager say to the inspectors is mirrored by what staff and patients say. Spend time with staff to ensure they understand what a visit involves and what they might be asked. For more advice on this see: Preparing your staff for a CQC inspection.
Run a mock inspection if you can, either with one of your team being the inspector or ask a neighbouring practice or you could ask one of your patients to help. Running through what the inspection will look like from an outsider’s perspective will help clarify which areas need work. Practising questioning staff ahead of time will also help them to feel more confident on the day and prepared for what they may be asked.
The CQC will want to look at your staff folders to make sure that staff are thoroughly checked before they start work and that they are appropriately trained and supported when at work. Go through all of your staff files to ensure that the correct paperwork is filed. See Ensuring your HR records are ready for a CQC inspection for more on this
Ensure that you have a list of courses that clinical and non-clinical staff must undertake. The CQC does not mandate which training staff must undertake, but it will expect that all new staff have a list of mandatory training and that this is refreshed at regular intervals. All staff should have annual appraisals and a personal learning plan and these should be available for inspectors to look at.
Staff training is important to ensure that staff are competent to fulfil their role so it is a good idea to log what training opportunities there are and a log of any internal or informal training done as a practice.
Prepare your patients
Your patients are your biggest asset and the inspectors will be interested in talking to patients to get their views. Talk to your PPG, ask if anyone would be happy to attend on the day of the inspection, ask them for their views on the CCQ’s key lines of enquiry and what they feel are the practice’s strengths and weaknesses.
The CQC will be keen to talk to members of your PPG and see patient feedback. Highlight any projects which have involved patients and look for how you can demonstrate that you listen to your patients and respond to their feedback.
The CQC will also be interested to see that you understand your patient population and how you support particular groups such as carers, patients with dementia, those with long term conditions and so on. It is a good idea to think of examples where you can demonstrate additional support to specific patient groups such as a coffee morning for carers, doing personalised recalls for cancer screening or patient education events.
The CQC will want to see that your practice premises are fit for purpose, that they are safe and that you have good governance procedures (medicines safety, infection control, fridge monitoring etc). There is a lot involved in ensuring that you tick all the boxes with regards premises, so make sure that you have responsibilities assigned and enlist a team of people to help with decluttering and deep cleaning ahead of the visit. Our practice walkthrough checklist can help with this.
One of the key themes that emerges from the key lines of enquiry is ensuring that there is joined-up care for patients. Make sure you document multi-disciplinary team meetings and follow up on actions. Think of examples or case studies of patients whose care has been improved through a team approach. Think about how you include the patient in their care and provide copies of care plan or letters so that patients have information about their care.
Understand your practice statistics. The CQC will look up your data before arriving and will be keen to explore any areas where you differ from the average. Look up your immunisation, screening and QOF rates. Understand your prevalence.
How are you reviewing your data with your peers to improve? The better you understand your data the better you will be able to spot trends and the reasons for them. Think qualitative as well as quantitative. Non-clinical audits such as a review of complaints and the themes that emerge will also help demonstrate that you understand your practice and act on feedback to improve services.
What makes your practice stand out?
The case studies of practices awarding outstanding have all demonstrated a project where they have gone the extra mile for their patients. What examples do you have of your practice running an innovative project or demonstrating improved patient outcomes? CQC visits are daunting but they are also an opportunity to demonstrate the good work you are doing and an opportunity for you to potentially improve your rating.
Meeting the key lines of enquiry
Our checklist of suggested evidence to demonstrate you meet the key lines of enquiry can help practices identify information that they might want to gather to present to inspectors. This list is not exhaustive and you may well have better examples of how to demonstrate that your services are safe, effective, responsive caring and well led. You can find the checklist here.
The following resources on Medeconomics can help you prepare for the inspection:
- Preparing your staff for a CQC inspection
- Ensuring your HR records are ready for a CQC inspection
- Policies to check ahead of a CQC inspection (a checklist)
- Paperwork to prepare for your CQC inspection (a checklist)
- Evidence to demonstrate how the practice meets the CQC's key lines of enquiry
- Practice walkthrough (a checklist)
Fionnuala O'Donnell is a practice manager in Ealing, West London, and a CCG board member