During a CQC inspection, inspectors will want to check that your practice against its key lines of enquiry, which relate to whether the practice is safe, effective, responsive, caring and well-led.
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.
Below are some suggestions of evidence you could collect to demonstrate how you are addressing each of the five key questions in your practice.
How do systems, processes and practices keep people safe and safeguarded from abuse?
- A comprehensive safeguarding children and adult policy which includes how the practice applies the Mental Capacity Act and Deprivation of Liberty Standards, how it deals with female genital mutilation and how the Prevent strategy is applied).
- Ensure that you have a safeguarding children and adults lead (it doesn’t have to be the same person) who is responsible for keeping up to date with the latest guidance and disseminating this to the whole team.
- Child protection and vulnerable adult register, and evidence that these registers are regularly reviewed and actioned.
- Minutes of meetings where child protection and adult safeguarding meetings are discussed.
- A locum pack which has the relevant local contact details and/or posters in clinical rooms with safeguarding contacts.
- Medical alerts from MHRA, clinical alerts from CCG or NHS England and missing children reports sent from the local authority are logged, disseminated to all relevant staff and acted on where necessary.
- Infection control reports and action plans.
- Health and safety and fire risk assessments.
- Staff have been DBS checked as appropriate.
- Evidence that the practice has reviewed what constitutes a safe staffing level (minimum number of clinical and non-clinical staff needed) and that there are contingencies if there is an unexpected staff absence.
- A business continuity plan, training for all staff on what to do in an emergency and practice simulated urgent scenarios. Ensure that the plan is updated regularly.
- Where locums or agency staff are used, proof that employment checks (right to work in the UK, DBS check, indemnity, mandatory training) have been completed by the agency and copies provided.
- Evidence that all staff understand the consent policy.
- Evidence that the practice has looked at the best use of skill mix and that all staff perform within their competencies. For example, if a practice has an HCSW there is evidence that HCSW has a signed off care certificate and that any enhanced skills such as simple wound care or enhanced diabetic foot checks have been assessed and signed off by the relevant clinician.
- Evidence on how information is handed over between shifts to ensure important messages are passed on.
- Evidence of data sharing agreements where appropriate. Evidence that all staff understands these agreements and understand how to share information safely.
- Evidence that the practice has completed and acted on the Data Protection and Security Toolkit. There is advice on this here.
- Evidence of staff training on information sharing, consent and information governance.
- Evidence of the care planning process - how are care plans and treatment plans shared between services?
- Health and safety policy and risk assessments.
- Equipment maintenance logs and PAT testing.
- Legionella testing records.
- Significant event policy and evidence of significant events being written up and discussed in meetings.
- Patients’ complaints log, evidence of replies to patients’ complaints and an annual review where all complaints are discussed. Consider writing a report of the themes that have been raised and an action plan for making improvements
- Understanding the duty of candour.
Are people’s needs assessed and care and treatment delivered in line with current legislation, standards and evidence-based guidance to achieve effective outcomes?
- Evidence that the practice regularly reviews and discusses clinical guidance to ensure that all clinical staff are operating according to latest guidance and best practice.
- Evidence of safety netting and how patients are advised to seek help if their condition worsens.
- Evidence of peer review and that any changes to regular management are documented. Evidence that updates and learning is shared between the team.
- Evidence that the practice reviews its performance on QOF, the outcome indicators on the primary care web tool and any other tools used by CCG or local area team are reviewed, reasons for distance from the average discussed and documented and action plans put in place to improve performance where necessary.
- Evidence that the practice reviews its performance – the Public Health England website https://fingertips.phe.org.uk/ is useful for this. Your CCG or area team will also be able to provide comparative data. Document any reasons for distance from the average and any action plans put in place to improve performance where necessary.
- Demonstrate an understanding of the Mental Capacity Act and Deprivation of Liberty Standards.
- Evidence that the practice monitors its performance and compares itself with its peers.
- Clinical audits - make sure you have two fully-completed audit cycles.
- Minutes of any locality meetings where peer review is discussed
- Review of prescribing data and comparison with other practices.
- Patient feedback (friends and family test) PPG surveys, NHS choices and suggestions are regularly reviewed and acted on.
- HR folders with all necessary documentation. See here for more on this.
- Evidence of in house training and courses staff members have participated in
- All staff are able to articulate how their learning needs are met and how the practice supports them to develop.
- Information on what training is available locally and how the practice decides on training plan for different staff groups.
- Performance management policy.
- Induction policy.
- Evidence of good team work - think of examples or case studies where you can demonstrate different staff worked together to improve patient care.
- Evidence of multidisciplinary meetings and actions from meetings documented and followed up.
- Examples of care plans where different teams have inputted into care plans.
- Examples of working with voluntary sector e.g. carers services, to provide a holistic service.
- Evidence of the practice's approach to patient education, how does the practice use information screens, posters and leaflets.
- Evidence of PPG activity.
- Evidence of health promotion activities.
- Evidence of any staff attending MECC (make every contact count) training.
- Description of practice approach to proactive care, how is the recall system for NHS health checks set up. Does the practice maximise opportunities to promote cancer screening?
- Support for carers.
How does the service ensure that people are treated with kindness, respect and compassion, and that they are given emotional support when needed?
- Friends and Family Test, NHS Choices and any other positive patient feedback.
- Looking after homeless patients, refugees and asylum seekers or other specific groups.
- Evidence the practice meets the fundamental standards of care.
- Examples of how the practice ensures high quality end-of-life care.
- Examples of how the practice cares for people with dementia.
- Examples of how the practice cares for people with learning disabilities.
- Examples of how the practice looks after and supports carers.
- Examples of shared decision making.
- Evidence of communication given to patients to help them understand their care - e.g. giving patients copies of referral letters and giving them a copy of their care plan if they have one.
- Evidence of how the practice meets its obligations under the Accessible Information Standard such as easy read, large print or braille communications.
- Information about local advocacy services, evidence of how patients are supported to access these.
- Carers register and evidence that it is kept up to date.
- Evidence of support provided to carers.
- Reasonable adjustments for disabled people.
- Evidence of privacy and dignity and chaperone training.
How do people receive personalised care that is responsive to their needs?
- Evidence that the practice understands its population (breakdown by age, gender and ethnicity) and an understanding of population prevalence.
- Evidence of how the practice is flexible (range of appointment times, clinicians, services offered).
- Explanation of how reception accommodates requests for appointments for children and vulnerable or high risk patients.
- Details of how the practice prioritises home visits.
- Evidence of how the practice offers choice and continuity of care
- Premises appraisal and risk assessment.
- Evidence that premises meets all relevant legislation (Disabled access, legionella testing, PAT testing etc.)
- Explanation of how appointment system works and rationale for numbers of routine and urgent appointments.
- Explanation of how urgent needs are identified and prioritised.
- Explanation of how late running clinics are handled and how this is communicated to patients
- Evidence of patient feedback around appointment system and how this is managed.
- Complaints policy.
- Minutes of meetings where complaints are discussed.
- Report to summarise key themes raised by complaints in previous 12 months and action plan for improvements.
Is there the leadership capacity and capability to deliver high-quality, sustainable care?
- Explanation of organisation structure and leadership development, evidence of good team working.
- Personal development plans of leadership team.
- Any strategy or planning documents you have that highlights the strategy that underpins the practice.
- Evidence of succession planning.
- Evidence that staff understand the mission statement of the practice and their role in contributing to the vision.
- Evidence that staff are supported and valued.
Fionnuala O'Donnell is a practice manager in Ealing, West London, and a CCG board member
Other useful articles
- Preparing for a CQC 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)
- Practice walkthrough (a checklist)