From 1 April 2013 all General Practices had to be registered with CQC. In addition to dealing with CQC registration issues, GPs will now also have to be prepared for CQC inspections. GPs and Practice Managers are already familiar with Quality and Outcomes Framework (QOF) inspections. But there are some significant differences between the two types of inspection. QOF inspections focus mainly on the documentation of clinical care. Whilst this is important to CQC inspectors, record keeping is only one of the 28 ‘Essential standards’* which they examine. Moreover, whilst a low QOF score may have a hugely detrimental financial impact on the practice, a negative CQC inspection report could lead to enforcement action, which in the worst case scenario could mean a practice’s CQC registration being cancelled. It is thus important to be prepared for CQC inspections.
How to prepare for a CQC inspection
- You may not get any warning of the inspection. CQC have made it clear that there will be 3 types of inspection for GPs: 1) Scheduled inspections 2) Responsive inspections and 3) Themed inspections. You will receive at least 48 hours’ notice before a scheduled or themed inspection. However, you won’t usually get any notice before a responsive inspection as these occur as a result of concerns which have been raised.
- It will be important that you are able to demonstrate compliance with the regulations which are the statutory framework behind the ‘Essential Standards.’ Practice Managers should be making sure that they can evidence this with appropriate documentation, including clinical records and relevant up-to-date policies. CQC inspectors tend to focus on 4 or 5 of the ‘Essential Standards’ at any one time. Some areas, such as respecting service users, consent, care and welfare, safeguarding, record keeping, training and assessing and monitoring the quality of the service provision are viewed as particularly important. However, an inspector could decide to look at any of the ‘Essential Standards’. For example, you might be able to use positive responses to patient surveys in order to help you show that service users are being respected and that this outcome is being complied with.
During a CQC inspection
- Typically, two inspectors attend for an inspection, though it could be just one or several. The CQC inspectors should explain what the nature of the inspection is and which of the ‘Essential Standards’ they intend to focus on.
- CQC inspectors will ask you for copies of relevant documentation. They have the right to do this, but make sure that you take a copy of any documentation first.
- CQC inspectors can also speak to staff and patients (with their consent).
- It is important to be helpful and it is an offence under section 63(7) of the Health and Social Care Act 2008 to obstruct an inspection.
- Keep a note of anything that the inspector says or anything you say during the inspection so that you have a contemporaneous record if there is any dispute later. You are entitled to feed back at the end of the inspection.
After a CQC inspection
- You should make a formal complaint if there are real concerns about the professional conduct of the CQC inspector. If a CQC inspector has been rude or overbearing, it may be useful to take a statement from the relevant person as soon as possible, to back up a formal complaint.
- You will receive a written report following the inspection. You will have the opportunity to comment on this and will be set a deadline for serving any responses to the inspection report. It is important that you comply with the deadline. Make sure that you go through everything in the report line by line, and that you indicate everything you disagree with in your response, together with the reasons why and supporting evidence.
- If CQC is still not happy about your compliance in one or more areas, then you could be served with a warning notice or even a notice of proposal to cancel your registration. You will be given short deadlines to respond to each of these notices too, so again, it is very important that you respond to these notices within the designated time-frame, and that you challenge any matters which you disagree with. Failure to do so at the time could be used against you in subsequent proceedings.
If at any stage you need help in dealing with CQC or responding to any documentation they serve on you, then it is best to seek expert legal advice. If you wish to seek legal advice do so quickly, so that your legal advisors have time to take instructions for you before any deadlines need to be met.
* See http://www.cqc.org.uk/organisations-we-regulate/registering-first-time/essential-standards for further details. You can also write to CQC to request a copy of the book ‘Essential Standards of Quality and Safety’ which sets out the guidance in more detail.