The Care Quality Commission (CQC) is an executive non-departmental public body of the Department of Health and Social Care of the United Kingdom. It was established in 2009 to regulate and inspect health and social care services in England.
According to the government and the NHS Confederation, CQC is pivotal in driving up care quality “through effective regulation and registration against its essential standards” and is responsible for “informing best practice”.
Further, they have the sanctions and enforcement power to ensure that; if care providers are failing to meet fundamental standards of quality and safety; they are held accountable, improved or in some cases shut down. The CQC also assigns ratings and publishes reports on care services. This allows the public to make informed decisions when choosing from care providers.
Recently CQC have altered the way in which they conduct their inspections and audits of health care providers, and they have introduced the telephone call inspection, where by they ask a series of questions, and require evidence based answers, where health care provider will still be required to submit evidence of the details being requested.
Healthcare providers should not fear, or be nervous of CQC inspection, in fact quite to contrary, it allows healthcare providers to be honest, to challenge their own shortfalls, and reflect on how they can better improve their ways of working to ensure that they comply with their legal and ethical requirements, and while I constantly hear practice managers and GP partners moaning about the level of due diligence paid by CQC, in truth, if the healthcare providers conducted their business in a way which is compliant with law, they would have no concerns, and the problem the healthcare sector has, is there is such inconsistency in standards between those who comply and those who do not.
We must all remember that CQC conduct themselves objectively and are driving standards across the healthcare system in the UK, which is something we should be thankful for (as we are all patients).
So in preparation for your next CQC inspection, by way of telephone call known as an Annual Regulatory Review (ARR), here are some top tips compiled for healthcare providers, and I have taken into account some of the details that even CQC give you in Nigel’s myth busters, so healthcare providers really should be utilising such valuable resources as those.
Preparation is the key, and there is no excuses for going into the call without having done your homework, because they are kind enough to give you the questions in advance.
When you receive the initial call to advise you of an agreed date for the ARR likely within the next month as a standard time-frame, it is essential to start to focus on answering questions from that point and gathering your evidence to support your answers.
For the review, over the telephone, it is a really good techniques to summarise your answers into easy read format, to that you almost convert them into a clear audible script to recite on the call when being asked the questions, and if you have time, rehearse this, practice with a colleague and get them to simulate the CQC inspector role.
There is an important factor, and that is that no one person delivers CQC on behalf of the healthcare provider, and thus it is integral to the success of your call that prior, you have engaged as many staff as possible. This give such meaningful insight into others role and perspectives on the current state of healthcare provisions and gives you access to valuable information at your disposal.
The questions are closely linked to what is new since your last inspection, and frankly speaking, be honest, they will know immediately if you are lying, or trying to cover things up, or that you are trying to act oblivious to the fact that your services may have stayed the same, or even gone backwards since the last inspection, and this is quite likely if you have had a high turnover of both clinical and non-clinical roles. However if you have made significant improvements and are performing well in areas, and continue to do so, then do not be shy to share this with CQC.
You will be asked explicitly regarding how you addressed any areas of concern which were noted in your last report, even if your rating was good, rather that requires improvement. I highly recommend reading the last report again and make sure that all improvements suggested have been completed and can be evidenced accordingly (as they will ask to see).
On a similar theme, inspectors will have looked at ‘safeguarding concerns’ and ‘complaints’, so brush up on them, in case they ask. I’m guessing this will be a more detailed conversation if issues have come to fruition for that healthcare provider, and bear in mind they are also aware of QOF and local contract performances, know your exception rates on QOF and why they may be high and what you intend to do this year to improve that?
Know about National Workforce Reporting System in particular, and make sure you comply with minimum data-sets, as CQC can question you on this, even if not on the questions they have sent, and they will do so if they have noted that you failed to upload data on the primary care web portal, such as year end complaints, workforce data, opening hours and extended hours data.
When the call is scheduled to take one hour, know that you should diarise double this time, and understand that 95% of the verbal transaction is you and not them. Be mindful that if you try to fly through the answers in order to get of the phone quick, they will sense your unease, and are likely to ask further probing questions off script.
The inspector will listen and type/write up notes as they go. This led to a few occasions of silence, but you get used to it. Do not attempt to fill this silence, again this may lead the inspector to believe you may be concealing something, or not revealing the truth to them.
Remember the call is yours, and your chance to be really honest about the provisions of care and this means to both patients and employees, There is absolutely no point in attempting to sell yourself as wonderful at patient care if your ratings are low and complaints are high, and you have toxic work cultures, you are better to spend the time acknowledging that, and what you intend to do about it, and by when, and who will be involved in driving it and delivering it. That if your chance to impress CQC. Be proud of your achievements, and be clear on the work still to do, as it is a continued process.
Inspectors like clear and evidenced examples to all of your answers, so if you are saying you have done XYZ, then give a recent example of it. You may also be asked about changes implemented based on the results of your own patient survey or the GP national survey.
Whilst it does say it on the CQC website, it is important to note that the telephone call cannot directly and immediately change your rating. However, if they have concerns this will immediately trigger a site inspection.
You will be notified if this is going to take place with the Annual Regulatory Review (ARR) report from CQC, which will be sent to the registered manager by email within the next week or so. If an inspection is required, this will take place within the next six months. However, you won’t know the exact date until two weeks before. If you are re-inspected, the slightly good news is this telephone call forms part of that inspection and as a result, you won’t need to submit any pre-visit information to CQC in advance of the inspection.
What we didn’t fully realise is an inspection could be triggered if CQC feels your quality has decreased or improved. For example, if you have improved dramatically from your last inspection, you may be re-inspected with the aim of increasing your rating,
I firmly believe that CQC is a valuable entity to support what healthcare providers do, and the standards at which they do it. Especially NHS healthcare providers, because they are public body and should be monitored. The issues seem to be how the inspections take place.
Therefore, this new telephone approach is good as it means everyone is measured against the same set of questions and criteria. While this creates a small additional piece of work each year, if you managed accordingly, you can use your first review as a baseline going forward. Plan to make a live document of ongoing actions from each CQC call, and compile as you go, so that the next time the call comes around you are immediately prepared in full.
If you require support or systems in order to deliver your services to the highest standard, or your require some support in CQC preparation, then our primary care consultants are here to help. Contact enquiries@your2020vision.co.uk or https://www.your2020vision.co.uk/contact
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