Preparing for a CQC inspection
I'm sharing here some tips I have learned over the years in preparing for a CQC inspection- both as a former practice manager, and from my role as Development Manager here at the LMC, assisting practices pre- and post-inspection.
Read What to expect on a GP inspection - this is essential reading and is a document prepared by the CQC themselves to assist GP practices.
Read the GP Provider Handbook (Jan 2016) - familiarise yourself with the five key questions/lines of enquiry and the six population groups.
Dedicate time on staff meeting agendas and PLT/training event to CQC issues, and spend time helping all staff members to understand what the CQC requires. Remember, the inspection team will spend a lot of their day talking to different members of staff from all teams within the practice- this is not to try and trip the management team up. Its purpose to to assess staff members' understanding of key policies, and how they might report any concerns to the management team.
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.
Make sure you have a recent infection control audit and any arising action plan to hand. They will ask to see your cleaning schedule and look in your cleaners cupboards. Walk round the practice and imagine you were a visitor- try and notice the things we become blind to in our own working environment- e.g. the dates on the disposable curtains, any damage to flooring, any mysterious stains on the carpet. If you do notice anything and you can't repair/sort it before the inspection- document a risk assessment and have the answers ready about your plans to deal with it.
Have your health and safety risk assessments to hand. Make sure you've done a fire drill in the last six months and that you have documented the weekly fire alarm check.
They will ask to see a personnel file. Make sure these are tidy and kept in a locked cupboard. Make sure you do not keep staff DBS checks in their file (record the date of disclosure, the disclosure number and the type (standard/enhanced). Make sure you have a copy of staff photo ID in their file- a copy of the NHS smartcard is sufficient, as staff have to provide extensive proof of identity when applying for their smartcard.
Keep a training matrix showing what training courses you expect staff to complete, when they have completed them and when they are next due. Check nurses and GPs are on the NMC/GMC register at least once a year, and keep evidence that you have checked. This includes the GP partners, too. A spreadsheet in the form of a simple matrix is an effective tool.
The GPs will be asked about audits the practice has done. Keep a central file of all audits done, and action plans.
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. Make sure any actions identified from a complaint or significant event were owned by someone senior within the team, and you can evidence they have been completed.
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.
On the day the inspection team will take a tour of the practice. They may look in cupboards, run their fingers along the tops of the picture frames, peer at the labelling on your sharps bins, check your external clinical waste bins are locked, peer into your fridges, check your temperature logs, and check expiry dates of medications and instruments they find in rooms. This may feel instrusive. It's always worth checking these things yourself before the inspection, to minimise any problems.
Read the Regulations- start with Regulation 17 - Good Governance. They contain clear guidance notes as to what success looks like.
For full overview see the "guidance" section for each of the CQC regulations.
Give your Practice/Business Manager and your Registered Manager protected time to compile all the documents the CQC require before the inspection.
You can expect the inspector to contact the practice manager before the date on the inspection. They will ask for a significant amount of evidence before the inspection- it's worth making sure this is in good order before being sent off. This is an opportunity to tidy up any policies and ensure they are fully reflective of what your practice does.
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. The CQC Mythbusters are extensive and contain the answers to many queries. Yes, there is one on Legionella!
You will be sent a sealed box and patient comment cards- encourage your patients to fill these in. The comments made by patients in the run up to the inspection are quite significant in helping the inspection team form a judgment of the care you provide, along with the national patient survey and any information you share on your own website about your patient satisfaction ratings.
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). The more comfortable, relaxed and welcome they feel, the more likely they will be to form a positive impression of your practice.
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 inspection 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! You will have an opportunity after the inspection to provide feedback. The inspector will leave you with a handwritten copy of key points, and you will have the opportunity to dispute factual accuracy when the draft report is produced. The day of the inspection is not the right time to raise issues with the CQC regime generally. A positive inspection can have a really great impact within the practice. The CQC have a target to get the draft report back to you within fifty days of the inspection.
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.