The last-minute delay in the implementation of the CQC’s new inspection methodology in December 2022 and the temporary pause in CQC routine inspections of GP practices over the winter months may cause GP practices to wonder what they can expect from CQC inspection in 2023 and what is happening with the development of the CQC’s new inspection methodology. We set out the latest developments below.
Frequency of Inspections
In December 2022 the CQC announced it was pausing routine inspections for GP practices in order to ease pressure through the winter months. Instead, the CQC focused on only inspecting GP practices where it received information indicating there was a ‘risk of harm’ to patients. While GP practices may have felt a slight reprieve in terms of CQC inspection, as of 1 April 2023 the CQC has reverted back to its ‘normal’ inspection practices.
The existing CQC guidance on how it monitors, inspects and regulates NHS GP Practices continues to refer to the following inspection frequencies and activities:
- Re-inspection is carried out within 6 months of an Inadequate rating for any key question in line with the Special Measures regime;
- Requires Improvement, Good and Outstanding rated practices are subject to an annual regulatory review process and Provider Information Collection (this is a standard practice applied to all services regardless of rating).
- The CQC will continue to respond to new and emerging information of concern which may indicate an inherent risk in a service.
- The CQC will also continue to carry out monitoring calls with GP providers where a monthly review has indicated a need for further follow-up.
It is worthy of note that the CQC’s new inspection process has indicated a scrapping of ratings led inspections. However, it remains unclear whether this will apply to services in the Special Measures regime (or if the Special Measures regime will continue to be used) and how this will be managed under the new process. Clarity on this point is still required given the CQC’s current ambition to roll-out its new single assessment framework methodology in late-2023.
Provider Information Collection (‘PIC’)
The CQC is currently continuing to collect specific information through the annual PIC process. The PIC involves a phone call where the inspector asks a set of standard questions which help inform its decision making.
Little information has been shared by the CQC so far in relation to whether it intends to continue PIC’s in light of its new inspection methodology. However, during a recent CQC Webinar it was mentioned that the process of requesting information is likely to be much more dynamic and focused than it is currently. It was noted that there will still be circumstances where inspectors will need to proactively request information from providers, particularly where there are gaps in knowledge or national data sets, although whether such requests would follow the same cycle as the current PIC’s was less clear. It was also noted that the CQC has been working with national partners in the background to see how they could share information more effectively to avoid repetitive requests.
New Assessment Framework
The CQC’s new policy consists of a new single assessment framework for all service types at all levels. It looks to introduce new technology to make it easier for providers to interact and share information with the CQC. A simple breakdown of the framework is provided below:
- The four-point rating scale and the 5-key questions remain the same.
- 34 quality statements, expressed as ‘we’ statements, will replace the existing KLOEs. Grouped under each of the 5-key questions, the statements describe what good care looks like and will link to the regulations.
- 6 evidence categories to organise information under the quality statements have been developed. This includes evidence such as observations, feedback from staff, people’s experiences, outcomes and policies and procedures. The purpose of the categories is to ensure clarity about what constitutes a sufficient amount of evidence to inform a view about the quality of care being delivered in a certain area and to better ensure consistency.
- A scoring system has been developed (replacing the existing ratings characteristics) to determine judgements and ratings. Inspection teams will assign scores to evidence collected. This is intended to allow more transparency, help ensure consistency and further the CQC’s ambition to support providers to improve.
While the CQC will still be carrying out on-site inspection, there will be a shift towards remote evidence collecting activities, with the CQC collecting evidence on an ongoing basis, which will allow it to change ratings without carrying out a physical inspection. In the future, inspection reports are intended to be much shorter and simpler.
Provider Portal
The CQC continues to consult on its new assessment framework with the latest step focusing on the development of a new Provider Portal. It is currently testing its existing technology with a small number of providers and developing the technology on feedback received. The portal is intended to be a hub for communication between the CQC and the registered provider with a move away from email communications.
Eventually, GP practices should be able to make registration changes, submit notifications, actively share information and access and update data the CQC holds about their practice through the portal. The CQC hopes the new portal will be a one-stop-shop for communications and build a robust process for having good conversations about the data the CQC holds, assisting with the sharing of information.
The CQC intends to roll out the new provider portal in stages from Summer 2023. Providers will be notified individually when they are able to sign up. It is intended that by the end of the year all online interactions between the CQC and providers will be carried out through the portal.
The CQC has indicated its intentions for the portal to be an intuitive, easy-to-use system allowing different levels of access between individuals within an organisation. It hopes the two-way information sharing process will allow it to assess and update ratings more frequently in line with the single assessment framework and help inspection teams better appreciate an individual practices’ performance over time.
The provider portal is a key development within the CQC’s new assessment framework. GP Practices should keep abreast of developments in this area to ensure they can use the portal to the best of their ability once it is launched. It is likely that practices who more actively engage with the portal will have a better chance of influencing future ratings awarded through the inspection and assessment process. For example, reviewing and responding to evidence collected by the CQC to provide further context or actively seeking to collect positive feedback from patients and partners and sharing this with the CQC.
The current aim is for elements of the new provider portal to be gradually rolled out more widely from August 2023 onwards.
Challenging CQC Inspection Reports
We know that the CQC is developing an ‘improved process for checking the factual accuracy of draft reports’ but beyond this statement, very little information is known. It is not even known whether the process for challenge will still be referred to as the factual accuracy comments process, let alone how it will work in practice. We do know, however, that the CQC intends submissions to be made through the new provider portal once fully developed. Providers should expect further information on new processes to be released later in the year.
Currently, the existing factual accuracy comments and rating review processes remains in place.
CQC Enforcement
The existing CQC enforcement policy and enforcement decision tree documents were last updated in February 2015 and January 2017 respectively. The CQC has indicated it will be making changes to its current enforcement process but no official statements have been released in relation to this other than a confirmation that, to allow more time for testing, it has taken the decision to move back the rollout of its ‘improved enforcement process’. No specific timeline has been provided for this. As noted above, it is unclear whether these changes will involve a change to the existing Special Measures regime.
Conclusion
While the CQC considers pressures on GP practices have now eased given the change in season, practices now have the additional pressure of not only assisting and responding to a CQC inspection but also keeping up to date with developments in the CQC’s new assessment framework. It is recommended that practices start thinking about how they can actively engage with the new provider portal later this year and consider who will be best suited to monitor and manage communications with the CQC through the portal.
