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The Ongoing CQC Consultation

Wednesday 25th Jun 2014 - Kate Hodkinson

I would hope that all practices are, by now, aware of the changes happening in regard to CQC regulation and inspections. The pilot projects in 12 CCG areas are now underway and inspections are beginning to take place. We will, hopefully, know some of the results of these in July before a second wave of pilots and the whole new inspection model goes live in October.

Several consultation events were held around the country and everyone was also given the opportunity to give on line feedback to the CQCs proposals.

The latest CQC information

The provider handbook for NHS GP Practices consultation document, available on the CQC website, has clarified many of the proposed changes to the inspection process and the proposals are currently being tested in the pilot areas.

The Five Key Questions;

  • Is it safe?
  • Is it effective?
  • Is it caring?
  • Is it responsive?
  • Is it well led?

These are already being used in many areas that CQC regulate and inspect – and the new judgement ratings.  Some individual aspects of service have been given the top rating; no overall inspection report has rated a service outstanding, yet.

CQC's New Operating Model

CQC Consultation

This diagram highlights the CQC’s new operating model including their new mechanisms for intelligent monitoring.  Their consultation has also outlined a much more proactive approach to gathering evidence and patient engagement and feedback. CQC will visit a CCG area twice year and during that visit they will inspect a range of NHS and adult social care services, aiming to get a much more holistic picture of the delivery and coordination of care and the overall patient experience. CQC are looking at four main sources of evidence:

CQC Consultation

The CQC will contact practices before a visit to the CCG area and request information to help prepare for the process. This is not an exhaustive list but this is likely to include:

  • Results from patient surveys
  • Their statement of purpose
  • Summary of the previous 12 month’s complaints and action taken
  • Summary of serious adverse incidents and action and leaning points
  • Significant events analysis
  • Evidence of how quality monitoring is carried out
  • Evidence of supplying urgent or emergency medicines

The inspection itself will focus on the five key questions and practices will be rating against these across 6 population groups:

  • Older people – over 75
  • People with long term conditions
  • Mothers, babies, children and young people
  • The working age population and those recently retired
  • People in vulnerable circumstances
  • People experiencing a mental health problem

The inspection team, which will include a GP and possibly a trainee GP, a Practice Nurse, Practice Manager and member of the public, will ultimately award a rating across each of these areas as shown on the table below:

CQC Consultation

The Inspection team will be focusing on Key Lines of Enquiry (KLOEs) - a standard set of questions and prompts that describe what a “good” service looks like. This approach is designed to give greater levels of consistency and standardisation to the ratings.

How to prepare for a new CQC style inspection

The big question for practices, and particularly the manager, is “Do I need to do anything now?”

I would suggest that one of the most important issues is to keep up to date with CQC information and how the pilot projects are going. Make sure you have read the consultation documents and understand the new inspection focus.    The basis of the legislation and regulation that underpins CQC requirements will remain in place. The big unknown area really lies in the evidence that will be required to demonstrate that you are meeting the Five Key Questions. Read the Key Lines of Enquiry documents and start considering how you would demonstrate them. The input of your practice team, including the clinical and administrative parts, and your patients will be much more crucial than might have been the case previously. So it is vital that they are fully prepared.

Recent CQC report on responsive visit

I was very interested to read this report on a practice in Kent. CQC carried out a responsive visit after concerns were raised and found a practice with a number of problems.

This highlights to me the importance of structure, control and record keeping. Simple procedures that many practices see as second nature are still not common everywhere – issues such as  recruitment processes, staffing records, training plans, employment checks, record keeping.

CQC can make unannounced visits if they have concerns about the quality or safety of care and when they start looking they will be very thorough. It is so important that practices take control of these types of issues early and don’t wait until you get notice of a visit. The new Five Key Questions and Key Lines of Enquiry will focus the inspection teams much more on areas of management and control as well as the experience of patients.

Make sure your practice is ready – no one wants to be named in the press in this way.

How are we tackling the changes?

Here at the FPM Group we are working to ensure that all our CQC products and services are in line with the new CQC changes that go live in October. Our team is constantly in talks with the CQC, Practice Managers and CCGs to make sure that we have the latest updates so we can rely it back to you.

The FPM Group offers a wide range of CQC products and serviced that are designed to aid GP Practices with their CQC compliance. For more information on how the FPM Group can support your practice please get in touch


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