At present, the Care Quality Commission (CQC) inspects approximately 10% of providers of primary care dental services.
Unlike the other sectors they regulate, CQC do not presently give ratings to primary dental care services. However, the report of their inspection will be published on the CQC website and CQC have enforcement powers available to them in the event concerns are identified which are linked to a breach of a regulation. It is therefore important that you are well prepared for an inspection and know what to expect from it in order to ensure the best outcome for your service. This article will set out what you can expect as well as some tips for ensuring the inspection runs smoothly.
Inspections will assess the service against CQC’s five key questions asking are they:
- Responsive to people’s needs?
Inspections will be led by a specially trained dental inspector who may be accompanied by a specialist dental advisor.
There are two types of inspections: comprehensive and focused.
Comprehensive inspections are usually announced two weeks before the inspection and will address all 5 of the key questions set out above. Comprehensive inspections will generally last one day at the practice and the inspection team is likely to include a specialist dental adviser.
Focused inspections are carried out as a follow up to a previous inspection, or in response to a particular concern. As such they may be unannounced inspections. Focused inspections will not address all five of the key questions and the composition of the inspection team will depend on the concern being followed up. A focused inspection may be carried out in conjunction with one of CQC’s partners, for example NHS England.
Before an Announced Inspection
More than two weeks before the inspection:
- The regional inspection teams will liaise with your NHS area team to gather information about the practices in your area, for example any complaints received, assessments undertaken or investigations carried out.
- CQC will ask your local Healthwatch for any information they have about the quality of care provided by the practices in your area, including evidence of good quality care and any concerns.
Two weeks before the inspection:
- The CQC inspector will call you to introduce themselves and talk through what will happen on the day of the inspection in more detail so you can prepare. Your preparation should include refreshing yourself on the content of the Provider Handbook for Primary Care Dental Services.
- You will receive a letter from CQC to confirm the date of your inspection and to request a copy of your statement of purpose, information on complaints/compliments and staff details. You will normally be given a deadline to respond to CQC’s request for information and you should ensure that you provide the requested information in good time.
- CQC will send you comment cards for your patients to complete and posters to advertise the inspection, telling patients how to share their experience of your service with CQC. You should ensure that patients are encouraged to provide feedback about your service.
On the day of the inspection:
- At the start of the visit, the Inspector will meet with the registered manager for a short introductory session to explain how the inspection will be conducted. You should ensure you set aside some time for this and use the opportunity to tell the inspection team the things you feel that you do well at the service.
- The inspection will combine interviews with staff and patients, collecting and reviewing the comments cards that people have completed and reviewing various pieces of documentation within the practice. The documentation reviewed could include: equipment maintenance certificates, your radiation protection file, audits and action plans, policies and procedures in relation to infection control and staff recruitment, staff training records and patient satisfaction surveys and findings. You should ensure this information is up to date and accessible to the inspectors to allow you to easily demonstrate how your service is safe, effective, caring, responsive and well -led.
At the end of the inspection:
- The inspector will provide feedback to the registered manager (or most senior person in charge as agreed at the outset of the inspection). This will be high level initial feedback only however, it is important that you keep a record of it as it may be relevant should you need to challenge any of the findings during the factual accuracy stage. Accordingly, you should take good notes of the feedback session or even consider bringing a colleague to the feedback session as a note-taker.
- The inspector should cover their findings to date although these will not be their final conclusions as they will carry out a further analysis of all the evidence following the inspection.
- If there are any matters with which you do not agree you should raise them with the inspectors at the time and follow it up with supporting evidence where relevant as soon as possible.
- The inspector should outline any issues that were escalated or require immediate action and outline any plans for follow up or additional visits (unless these are to be unannounced). In the event enforcement action is being considered you should consider seeking legal advice as soon as possible.
- The inspector should outline the next steps, including factual accuracy checking of the draft report (see below) and answer any questions from the practice.
After the Inspection- The report and Factual Accuracy Comments
After the inspection, CQC will produce a draft report which will be structured to reflect the five key questions set out above. It should also include information about notable practice and will set out any evidence about breaches of the regulations.
The draft report will be sent to you for you to provide your factual accuracy comments. This is your one chance to challenge inaccuracies within the report therefore it is important that you respond to CQC within the deadline specified (usually 10 working days) with your comments and further evidence in relation to any matters which you consider to be inaccurate. When framing your comments, you should bear in mind that CQC ought to act proportionately, follow their own guidance and report accurately which would include providing evidence to support their statements and conclusions.
If you do have concerns with your draft report then you may wish to seek legal advice and assistance with the factual accuracy process. In these circumstances you should bear in mind the deadline set and ensure you seek advice promptly to ensure a timely response to CQC.
Once the factual accuracy processes complete and any changes have been made to the draft report it will be published on the CQC website.
Further information about CQC inspections can be found at www.cqc.org.uk/dentalproviders.