Whilst it’s impossible to determine how inspections of GP practices will look once the CQC’s single assessment framework comes into play in the months ahead, it is always important for practices and the staff that work there to be prepared for an inspection. No matter what the changes are, there will still be an intense focus on care delivery and the way that care and treatment are recorded. Data will be scrutinised, patient experience analysed and key staff members interviewed. That may be done more remotely than practices are used to so it is important to consider the best way to make sure inspections are positive and successful experiences.
The inspection process can make many GPs and practice managers feel completely out of control, unsure of what findings the CQC will make and how this will impact the rating and reputation of the practice. By its nature, an inspection itself is not an experience that feels open or collaborative, but it does not have to be this way. There are a number of ways that GP practices can use CQC’s own guidance and the anecdotal experience of other providers to ensure that they are as prepared as possible.
Below are some key areas that practices should focus on and ensure are sound (from a regulatory perspective):
Training and Competency
We have seen a number of inspections where the CQC have strongly felt that there was insufficient evidence demonstrating that staff had received the appropriate and required training. Reports then go on to conclude that, on that basis, the staff are not competent and are placing patients at risk. In analysing those criticisms in a draft report (at factual accuracy stage), many practices discover that they do in fact have the evidence to show that training has taken place, but that it simply is either not held together in a way that can be easily accessed by the CQC or that it is spread across a number of files. As such, the inspectors could not (or indeed, would not) take the time to present the true picture. It is essential that documents can be accessed with ease during an inspection and that the practice is able to do itself and its staff justice.
In addition, GP practices will be required to show that relevant staff members, for example, advanced nurse practitioners or clinical pharmacists, receive regular one to one clinical supervision from the GP partners and that their patient consultations are reviewed by the relevant members of the practice management team. Many practices fall foul of the informal way in which they perform these reviews and supervisions and so it is important that practice partners and the practice manager can point to evidence that these supervisions are regularly scheduled, detailed summaries recorded and placed in the staff member’s file. This is essential evidence in demonstrating that staff carrying out clinical duties are competent and reassuring the CQC that the practice is meeting all regulations in relation to staffing.
The Recording And Use Of Patient Data
We have seen innumerable inspection reports in which the CQC complain about the way that GP practices record, interpret and present patient data (for example, relating to the uptake of screening tests etc.). These issues can range from the system that the practice uses (which may not be to the CQC’s taste but is very much to the taste of the NHS) to the way that data is used to drive and meet key performance indicators. It is important for Practice Managers (and the teams that support them) to regularly reflect on this data and consider it from the point of view of a person that has never seen it before and who needs to be able to understand it quickly. Data should be clear and comprehensive with relevant staff members able to speak about its relevance to the practice should the inspection team ask.
Where, in the opinion of the practice, the data is well presented and meets all relevant requirements but is still criticised by the CQC, then the practice should seriously consider challenging any negative judgements contained within the draft report through the CQC’s own factual accuracy process. It should not be that the personal preferences of an inspector have an impact on the way that a service is rated by the CQC.
The CQC is likely to contact patients directly to obtain information about their experiences and satisfaction. They may also consult the practice’s own feedback from patients. On that basis it is vitally important that firstly, the practice is proactive in gathering patient opinion and that, secondly, the practice reacts positively to consider and remedy any concerns raised as a result of the submission of those views. There is little value in being open to hearing about issues that patients may have faced as part of their experience if the practice has no intention of reacting in a positive way. The same goes for the way that the practice responds to patient complaints. Not only will the CQC want to see a detailed complaint register but it will also expect to demonstrate how the complaints have been followed up and resolved, with lessons learned by the practice.
Giving patients the opportunity to feedback and being able to resolve complaints or negative feedback quickly, will result in patients being less inclined to deliver a negative account of your practice directly to the CQC should they be contacted. Their feedback will be less about the issue that they felt the need to report and more about how positively the practice reacted and resolved the problem.
In a similar vein to gathering the opinion of patients, the CQC will also seek to understand the experience of staff members working at the practice. It is not uncommon for inspectors to dedicate time to 1:1, confidential discussions with staff during site visits. We have noted that during any inspection that involves discussions with an aggrieved member of staff, the focus of that inspection will quickly turn to the areas relating to their grievance. The CQC will often take the staff member’s feedback as fact without consulting relevant documentation or speaking to the practice manager to clarify areas of potential concern. There have been many occasions where we have seen statements from staff included in draft inspection reports such as “I haven’t been trained on that system” or “I have never had a supervision” but that can then be directly contradicted by readily available documentary evidence that the inspector has not asked for or reviewed. This can be addressed during a factual accuracy review but is potentially entirely avoidable.
In order to limit instances where staff may feel that venting to the CQC is their only option, practices should engage staff in regular feedback questionnaires and staff meetings. That way, any issues arising as a result can be quickly reviewed and resolved. Records of that feedback or minutes of any such meetings, alongside the resultant improvement work will go a long way to also demonstrating that the practice is “Well-Led”.
Attention given to these basic areas, alongside regular audits and mock inspections will ensure that GP practices are well prepared for regulatory scrutiny.