Under the new regulatory framework introduced by CQC, there has been a move away from the classic inspection as the main source of evidence about a service towards a broader “review of compliance” which considers all the available information relating to a particular service, of which the inspection or site visit is one element, assuming one is undertaken. There is no minimum annual frequency of inspection under the new system; it is a matter of discretion for CQC whether or not they carry out a site visit to a particular service. CQC states that a site visit will be undertaken when there are concerns or gaps in CQC’s information and it is seen as the most effective way of gathering additional information.
CQC has issued internal guidance to its staff about how inspectors should carry out site visits. Ridouts has obtained a copy of this guidance under a Freedom of Information Act request. If you would like a copy of this guidance please contact us on email@example.com.
This article highlights some of the key messages that CQC is conveying to its inspectors in its guidance about how site visits should be conducted:
- Most site visits will be unannounced. CQC guidance states that visits should not be a burden on the provider.
- The focus of the site visit should be on outcomes for people who use the service and what their experiences are. CQC inspectors should listen to and observe people using the service and to see how staff care for them. As a guide, inspectors should spend 50% of their time observing the care process, 30% talking with people who use services and the remainder of the time spent talking to managers and staff. In our experience, many inspectors are still focussing on paperwork, systems and inputs rather than outcomes. It is clear that a change of mindset is as much a challenge for inspectors as it is providers.
- At the beginning of the site visit, CQC inspectors should explain the areas they intend to look at and the tools they will be using to gather evidence. If the inspector plans to observe the premises, the manager or senior member of staff should be asked if they wish to accompany the inspector. However, the guidance says that when observing care or staff interactions, it is not appropriate to be accompanied. Further, if the inspector wishes to interview a service user that should be in private to ensure confidentiality and privacy is respected.
- If the inspector comes across a safeguarding issue, the person in charge should be informed and the inspector should ensure that action is taken to make the person safe. The inspector must then follow the CQC safeguarding guidance and send an alert to the local authority and/or the police as necessary. The inspector must also tell the manager if they believe a person is being deprived of their liberty without an authorisation from a supervisory body.
- There should be no surprises for the service provider when they get the draft report. In other words, there should be sufficient feedback. The guidance indicates that if the inspector has given feedback during the visit to the provider or staff, the inspector must ensure that the final feedback session summarises those findings. The feedback should include areas of strength or good practice, as well as areas for improvement, picking up the headline issues. Significantly, it is not supposed to be an opportunity for the provider to debate the findings or provide additional evidence. However, we are coming across cases where little or no feedback is being provided by CQC inspectors. It is critical that feedback is provided by CQC and recorded by the provider in order to enable an early response to be made to the regulator, prior to publication of the draft report, should that be deemed necessary.
It has been a matter of controversy in the press that over the last year that there has been a 70% reduction in the number of inspections undertaken by CQC. The response of CQC has been that this has not been policy driven but rather it was, in part, a consequence of the significant distraction caused by the re-registration process of last year. CQC is now saying that the number of site visits will increase significantly and that the expectation is that as part of reviews of compliance most services will be inspected. So be prepared!