Providers of health and social care services have always been anxious about receiving a knock on the door at 7am and being faced with a team of CQC inspectors raring to give the Home a “once over”. Traditionally this would involve the inspectors locking themselves away in a room and poring over the care records, training matrices and policies and procedures. Registered Managers would be asked to locate (quickly!) any paperwork that the inspector wanted to see.
Occasionally the inspectors would emerge from this intensive documentary analysis and make notes on their observations of the care being provided. The findings would then be delivered to the Registered Manager during a formal feedback session at the end of the inspection.
Providers often felt that the inspectors’ main task was to pick apart their records and note any gaps in MAR sheets, training records or care plans but recent times have shown that the focus of CQC has changed.
In accordance with CQC’s new inspection regime and its internal inspector’s guidance (obtained by Ridouts through a Freedom of Information request), the new focus of inspectors will be what they see and “experience” on the day.
The Inspector’s Handbook states:
“You should tell the senior person on duty that the emphasis of the inspection is on understanding the experience of people who use the service, and so you will focus on speaking with them and those people important to them. In addition, you will observe care practice and how staff interact with people who use the service”
The Provider Handbook for residential adult social care services mirrors this approach and lists additional inspection methods and other ways of gathering information during an inspection which are:
•Observing care (but not intimate personal care)
•Tracking individual care pathways
•Talking to volunteers, community professionals and other visitors to the service
•Looking at the environment including individual and communal rooms
It is telling that reviewing records comes last on that list. There is a clear shift in the approach of an inspector. Less emphasis will be placed on reviewing documentation and inspectors will be increasing, quite noticeably, the number of service users, staff members and family members that they speak to. This in itself creates a number of issues. We at Ridouts have seen a number of draft inspection reports that show the inspector noting a comment from a service user and using it as fact to criticise the Home. A good example is an incident where a service user with dementia told an inspector that they “wanted to go home”. This service user was then quoted in the draft inspection report in the context that service users were generally unhappy. Had the inspector consulted that service user’s care plan, they would have seen that this was a statement that she regularly made and was referring to her childhood home (her dementia led her to believe she was a teenage girl). This statement was challenged during the factual accuracy process and subsequently removed from the draft report by CQC.
This example draws attention to the fact that inspectors are now inclined to treat the views of service users and their families as an unquestionable and primary source of evidence. This is a flawed approach and where a statement is made by an individual that makes a negative assertion, documentary evidence should surely be sought to corroborate the statement.
The CQC has attempted to make clear that there has been a fundamental change in the way that inspections are undertaken. The Inspector’s Handbook encourages inspectors to explain to the provider or registered manager that they will not be looking for “compliance” but rather will be looking for “good” and interested in encouraging improvement. The same guidance reminds inspectors that the emphasis of the inspection is on “understanding the experience of people who use the service” and as such inspectors should focus on speaking with them and those people important to them.
It can often be surprising to Providers when they receive a draft report and see that a number of service users have made negative comments about the service, especially when these opinions will now form the basis of the inspection report. An effective way of limiting this level of surprise is by seeking feedback before the inspector does. This can be done through service user / family questionnaires, feedback boxes and by generally seeking feedback from service users during key worker or 1:1 sessions. The information gathered in these ways will enable providers to resolve any concerns raised as quickly as possible which will change the way that a negative statement is delivered by a service user to an inspector e.g. from “my tea is cold sometimes” to “I told the manager my tea was cold sometimes and they sorted it straight away”. Not only does this change the statement from a negative to a positive but it also shows the service to be proactively seeking the views of service users (which it should be doing anyway).
Finally, staff will be spoken to on the day of inspection and it is widely known that some staff members may not do themselves justice under pressure. This is entirely understandable but one way to limit this is to conduct mock inspections to get staff used to interacting with an “inspector”. Providers should also take steps to empower their staff and encourage them to demonstrate and be able to discuss the knowledge they have worked so hard to acquire.
High quality care along with positive relationships with staff, service users and their families will go a long way to fostering a sense of goodwill that hopefully will be shared with inspectors and conveyed in an inspection report.