Care Quality Commission
(February 2019) New CQC provider information collection & annual regulatory review
Practices should have now received the attached letter. Practices rated good/outstanding will no longer be routinely inspected every two years, with their inspections changing to a maximum interval of five years. Instead these practices will have an annual regulatory review including the outcome of a “ provider information collection” (PIC) with an annual phone call to the practice, as a satisfactory IT solution for the PIC has yet to be developed.
The GPC has worked closely with the CQC through various iterations of this in order to mitigate the impact on practices and our engagement has hopefully made the process considerably less burdensome and more fit for purpose
CQC Registration Fees Reimbursement
NHS England has agreed, as part of the new GMS contract for 2017/18, to reimburse GP practices' Care Quality Commission (CQC) fees from 1 April 2017. The details of the overall agreement in a letter to the service here and the requirement to reimburse CQC fees in the SFE (Amendment) Directions 2017 here.
Most practices pay their annual fee in a lump sum, but some make monthly installments. When practices send you a paid annual or monthly invoice, covering a registration period starting on or after 1 April 2017, please reimburse that invoice in the practice’s next regular payment.
Practices should send their invoice to NHSE Finance - email@example.com
The CQC's new approach
On their website the CQC say:
"Under our new approach:
We will put people who use services at the centre of our work – we will listen, involve and respond to people’s experiences of care.
Inspection teams will be tailored to the service it is inspecting – it will be led by an inspector with a GP on every inspection, and may include a practice manager or practice nurse and an Expert by Experience.
We will use Intelligent Monitoring to decide when, where and what to inspect, the methods for listening better to people’s experiences of care and using the best information across the system.
Inspectors will use professional judgement, supported by objective measures and evidence, to assess services against our five key questions:
Are they safe?
Are they effective?
Are they caring?
Are they responsive to people's needs?
Are they well-led?
We will rate services – these ratings will help people to compare services and to highlight where care is outstanding, good, requires improvement or inadequate.
Our inspectors will use a standard set of key lines of enquiry (KLOEs) that directly relate to the five key questions – are they safe, effective, caring, responsive and well-led? This will ensure consistency and focus on those areas that matter most."
What to expect on an inspection
This document is essential reading!
CQC Provider Handbook
It's worth taking some time to check through the 'mythbusters' on the CQC's website. They attempt to dispel some of the rumours and worries practices may have:
Never forget the CQC has legal powers underpinned by the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. This gives the regulator powers to enter a practice, impose sanctions and restrictions, and even (in extreme cases) to close the practice down immediately by revoking its registration.
How can the LMC help?
The registered manager can expect to be contacted two weeks prior to the inspection, usually by email. This communication will detail all the information the CQC require beforehand. If you are worried or concerned, give our team a call- we have hands on experience of inspections, and we can talk you through what you need to focus on.
Top tips for preparing for an inspection
- Read 'What to expect on a GP inspection' document
- Read the provider handbooks and familiarise yourself with the Key Lines of Enquiry
- Organise your policies, procedures and protocols so that you (and your staff!) can access them easily- remember to note the date they were last updated and when they are due for their next update
- Keep good records of your complaints (including the learnings you have made, and how these were shared with all members of the practice team) and likewise for your significant events
- Take minutes of all practice meetings- team meetings, significant events, complaints reviews, patient group meetings, palliative care, and have these to hand for the inspection
- Read the Regulations- start with Regulation 17 - Good Governance. They contain clear guidance notes as to what success looks like.
- Give your Practice/Business Manager and your Registered Manager protected time to compile all the documents the CQC require before the inspection
- If you are unsure what the inspector means- ask. Your inspector will make contact with you several times in the run up to the inspection- this is your opportunity to seek clarification and build up good rapport with them
- Co-operate with the Lead Inspector and other members of the inspection team. The more you help them, the easier it is for them to assess how well you are doing. It will be a long day for the Practice/Business Manager and the Registered Manager, but the inspection team are not trying to trip you up. Make information easily accessible to them. Be patient if they seem to ask the same thing more than once.
- Remember the inspection team are human beings- make them a cup of tea, show them where the kettle is, remember they may have had a long journey to get to you. Tell them where to park/how to find you. Try to find a space where they can meet up (although this can be a challenge, and they will understand if you just don't have a spare room for them).
- Brief your PPG on how they can help, and try to get the chair or another member of the group to meet the inspectors on the day. Tell the patients in the practice on the day of the inspection that you have inspectors in. The team may interview patients. Your patients are your best advocates!
- Take some time to prepare your presentation- this is your best opportunity to tell the inspection team about all the great things your practice does. They will already have had access to the GP Patient Survey results and your own website- use those 30 minutes wisely to tell them about the things they won't have seen yet. Remember to reference the Key Lines of Enquiry (Safe, Effective, Caring, Responsive, Well-led) AND the six population groups:1 Older people; 2 people with long-term conditions; 3 families, children and young people; 4 working age people (including those recently retired and students), 5 people whose circumstances make them vulnerable; and 6 people experiencing poor mental health (including people with dementia) - they will want to assess how well you perform for each of those groups.
- Be honest about your strengths and weaknesses- both in your presentation, and in discussions during the day with the insepction team. In those areas where you know you need to improve- tell them what your plans are to do so.
- Take some time to talk to your team about what the inspection team are looking for, and explain to different staff members about the kind of questions they may be asked
- Try not to be defensive!
- If you have real concerns on the day that the inspection is going badly, or you are unhappy with any member of the inspection team- contact the CQC immediately, and contact us- don't wait until after the inspection report comes weeks and months later to raise a concern. There is a defined complaints process, and inspections can be halted if necessary.
Preparing for CQC Registered Manager Interview
We have received a number of enquiries relating to issues with the Care Quality Commission (CQC) regarding changes to practice registration status. We thought it helpful to share the following guidance with practices, which is also available on our website for your future reference.
If a single handed GP enters into a partnership, or a partnership moves to single handed GP status, as well as notifying the CCG under the terms of your GMS/PMS/APMS contract, you must also separately notify the CQC. Registration issues can be complex and we advise you to contact the CQC for advice as soon as possible, to ensure your registration remains valid. The CQC treats individuals, partnerships and organisations as separate legal entities.
Where the CQC deems necessary, the practice may be required to complete a registration as a brand new provider, and this will require you to evidence the registered manager is a fit and proper person to provide services. Practices may nominate more than one person as a registered manager.
The CQC may well elect to conduct a face-to-face interview with the registered manager(s) prior to accepting the changed registration.
You can expect to provide assurance that the registered manager is:
- of good character
- is able to properly perform tasks that are intrinsic to their role
- has the necessary qualification, competence, skills and experience to manage the regulated activity
- has supplied documents that confirm their suitability
We link to a very helpful document developed by our colleagues at Wessex LMC to help registered managers prepare for the interview, including some potential questions you may be asked. This should be read in conjunction with the CQC Mythbuster No 35 - Fundamental Standards of Care . The Wessex document still references the ‘old regulations’, i.e. the Essential Standards of Quality and Safety that were replaced by the Fundamental Standards- but it is still a really simple, practical guide to preparing for the interview and the kinds of questions the registered manager will be asked.
The Fundamental Standards ensure compliance with the following two pieces of legislation:
- The Health and Social Care Act 2008 (HSCA 2008) (Regulated Activities) Regulations 2014 (as amended)
- Care Quality Commission (Registration) Regulations 2009 (Part 4)
Regulation 7 focuses on the requirements of a registered manager- this is what the CQC are trying to assess throughout the registration process.
The interview is not a formal inspection, but the interviewer may well ask to see:
- Individual policies, e.g. recruitment, training, medicines management, controlled drugs, cold chain, infection control, disposal of clinical waste, single use of instruments – have all policies at hand, either in paper or online format (they are happy to read from a screen)
- Samples of meeting minutes (staff meeting, clinical meeting, PPG meeting)
- A personnel file
- Your training matrix
- Your own patient satisfaction survey
- Copies of certificates of staff training
- Evidence GPs and Nurses are up to date with their appraisal/revalidation
- Evidence staff who require DBS checks have had them*
- Cleaning schedule
- Infection control audit
- Risk assessments
- A clinical record
*You should NOT keep photocopies of staff DBS checks in staff HR/personnel files. The CQC requires you to note the following details: date of disclosure, disclosure type (standard/enhanced) and disclosure number. A matrix or spreadsheet is acceptable.
The interviewer may well ask for a tour of the practice, so make sure all rooms are in good order. They may look in cupboards and fridges, so make sure thermometers and temperature logs are in situ and working. Make sure review dates on policies are recorded and are fairly recent.
It is advisable to ensure all policies reference the practice as named on their CQC registration. E.g. if the practice is known as Dr Jones and Partners and also The XXXX Health Centre- make sure your policies reflect the practice as it is named on the CQC registration.
Make sure all doors that should be locked are locked, sharps bins are stored appropriately and not over-filled, disposable curtains are labelled with the date and are within date.
Remember you can always call us at the LMC to ask for help and guidance in this and all matters CQC, on 0116 296 2950 or email us on firstname.lastname@example.org .
We are of the view the CQC’s requirements are onerous and disproportionate; however, their powers are enshrined in the Health and Social Care Act and getting it wrong can be hugely stressful and time-consuming for an individual practice. We can be present to observe inspections or registered manager interviews, subject to availability of an LMC officer.
LMC engagement with the regional CQC office
The LMC has improved its engagement with the CQC, in order for us to keep our members informed of key changes. The CQC has agreed to deliver two events to our members in 2018:
- Wednesday 20th June (FULL)
Wednesday 26th September
To reserve your place, please email email@example.com
Key documents shared by the CQC
- Fit person interview and what to expect
- Inspection Evidence Table (sample)
- GDPR Data security and protection – expectations for general practice
- Blank Evidence Table
The latest publication from the Care Quality Commission, “Driving Improvement”. Case Studies from 10 GP Practices”, 7 of which are from Midlands & East and demonstrate where significant improvements have been made.