John Canning Secretary Cleveland LMC July 2012

What is CQC? Care Quality Commission Replaced 3 previous regulators Mental Health Act Commission Healthcare Commission Commission for Social Care Inspection Duty to ensure services meet government set standards Funded by registration fees & government grant Presently undergoing internal review

CQC and GPs Government policy is that all services should be regulated Phased approach Private providers (including GPs) and social care, private GPs [registered with previous regulators] NHS providers Dentists OOH providers Ambulance providers NHS GPs

Registration for GPs Two elements Setting up an account Making the application Registration required from 1 April 2013 Protection for existing providers who register in the official window even if non-compliant

Accounts Do this now You will receive A letter with your login details A code which will allow you to start the application process You need to Set up an account Various people to enable data entry and sign off Choose one of four deadlines (between September and December 2012) to submit your application Set up accounts for various people to help you fill in the form and sign it off If you’re expecting to register with CQC and haven’t received your letter by the end of July, with your full contact details and we’ll send it to you.

The Application and Submission Window Electronic form Do not wait till near the deadline to start Can be done in stages

Terminology Individual Partner/Partnership Organisation Registered manager Nominated individual Regulated activity Location Service types Compliance Essential standards Inspections

Who registers Individual Sole practitioner Partnership The partnership You should have an arrangement to share liabilities Organisations Limited company LLP Social enterprise etc If uncertain ask

Registered Managers Required other than for individual registration Is in day-to-day control of one or more regulated activities NOT the same as a practice manager Usually be one or more partner(s)/director(s)

Nominated Individuals Not the same as registered managers Required for organisations Responsible for supervising the way that the regulated activity is managed Should be an employed director, manager or secretary of the organisation

Regulated Activities All practices Treatment of disease, disorder or injury Diagnostic and screening procedures Most practices Surgical procedures Maternity and midwifery services Some practices Family planning services Termination of pregnancies Few if any GP practices Nursing care Services in slimming clinics Transport services, triage and medical advice provided remotely Assessment or medical treatment for people detained under the Mental Health Act 1983 Management of supply of blood and blood derived products Accommodation and nursing or personal care in the further education sector Personal care Accommodation for people who require nursing or personal care Accommodation for people who require treatment for substance misuse

Service Types All practices Doctors consultation services Doctors treatment services Diagnostic and/or screening services Many practices Mobile doctors services Few practices Acute services Unlikely to include Prison healthcare services Hospice services Long-term conditions services Dental services Hospital for mental health/learning disability Hospital for substance misuse Hyperbaric chamber services Rehabilitation services Residential substance misuse treatment/rehabilitation Community healthcare services Community LD services Community MH services Community substance misuse services Urgent care services Care home WITH nursing Care home WITHOUT nursing Specialist college services Domiciliary care services Extra care housing services Shared lives Supported living services Ambulance services Blood and transplant services Remote clinical advice services

Location A place in which, or from which, regulated activities are provided or managed Each place if the regulated activities provided are managed independently Generally means each separate GP surgery, walk-in centre, etc is a location A single GP practice is one location Branch surgeries Include if associated with the main surgery the main surgery’s location Only if patients from the same registered list are seen or treated at all these places If the branch surgery treats patients from a different registered patient list to that of the main surgery, it will need to be included in your registration as a location in its own right More than one location requires one registration application with details about all locations

Fees Application is free Annual fee for maintaining registration GP Provider fee rates subject to consultation Suggest you respond OOH fees £800 for single location £1,600 for 2 – 3 locations

Essential Standards CQCs conversion of the Regulations into patient outcomes Standards and outcomes are best viewed as being interchangeable terms CQC has created prompts that provide further detail on the patient outcomes

Essential Standards I 1Respecting and involving people who use services 2Consent to care and treatment 4Care and welfare of people who use services 5Meeting nutritional needs 6Cooperating with other providers 7Safeguarding people who use services from abuse 8Cleanliness and infection control 9Management of medicines 10Safety and suitability of premises 11Safety, availability and suitability of equipment 12Requirements relating to workers 13Staffing 14Supporting workers 16Assessing and monitoring the quality of service provision 17Complaints 21Records

Essential Standards II 3Fees 15Statement of purpose 18Notification of death of a person who uses services 19Notification of death or unauthorised absence of a person who is detained or liable to be detained under the Mental Health Act 20Notification of other incidents 22Requirements for an individual or partnership providers 23Requirement where provider is a body other than a partnership 24Requirements relating to registered managers 25Registered person training 26Financial position 27Notifications – notice of absence

Standards and Registration Applicants make a specific declaration of compliance or non- compliance against 16 of the standards These are the standards that relate most directly to the quality and safety of the care you provide The remaining 12 standards relate to the routine day-to-day management of a service include certain notifications you must make to the CQC once registered No declaration of compliance with these in an application Still required to meet the outcomes

Non compliance At registration of an existing provider Can be registered for 1 April 2013 Declaration forms the basis of your legal registration with the CQC so it is important that your declarations are true and honest It is highly unlikely that CQC will refuse your application just because you declare non-compliance with any of the essential standards Registration may sometimes be subject to conditions If declaration of non-compliance against any of the essential standards Must submit an action plan of how to achieve compliance Action plan should be concise and succinct

Compliance Not necessarily straight forward May be achieved in more than one way Some very obvious Some by addressing the issue differently Take advice and consider option Is not achieved by having policies but by implementing them Keep records of why compliance is achieved

Compliant? GPC guidance takes GPs through each standard where compliance must be declared Full explanation of the 12 requirements Some examples

Inspections Regime not yet determined Likely to be a minimum of biennial Specific visits after concerns Some notice will be usually given Focus on outcome not policy

Possibly difficult standards 5Meeting nutritional needs 6Cooperating with other providers 7Safeguarding 8Cleanliness and infection control 10Safety and suitability of premises 12Requirements relating to workers

Meeting nutritional needs Only relevant where food and hydration are provided As part of the services provided This is not the case for most primary care providers No option to declare “irrelevant” Declaring non-compliance requires CQC to act as non compliance implies risk to patients As there is no risk you should declare compliance

Cooperating with other providers Patients will receive safe and coordinated care, treatment and support where more than one provider is involved, or they are moved between services A practice will expect to be compliant if cooperate with others involved in the care, treatment, and support of a patient when the provider responsibility is shared or transferred to one or more services, individuals, teams, or agencies; share information in a confidential manner with all relevant services, individuals, teams, or agencies to enable the care, treatment, and support needs of patients to be met; work with other services, individuals, teams, or agencies to respond to emergency situations; support patients to access other health and social care services they need

Claiming compliance? Discuss with patients the options and arrangements for referral Include in correspondence all of the information that would reasonably be required to treat the patient safely and effectively [see guidance for a list] When patients leave transfer the relevant information to the new provider(s) in a timely manner so that the needs of patients can be met in an appropriate timescale In the case of children and patients without the capacity to give consent, ensure that their parents/guardian/representatives are involved and informed about referral decisions When referring patients, ensure that patients know at least what type of information is being transferred Respects the right of patients to request information about them to be transferred to another provider unless there is a good reason for not doing so

Documentation An emergency preparedness plan including arrangements for sharing information and working with other providers Have a confidentiality protocol/information governance protocol that refers to information disclosures to ensure that data is transferred/received safely and securely A protocol for acting on correspondence and results, to ensure that your staff are able to respond in a timely manner to incoming information

At a visit… No good just having your policy document CQC is about demonstrating outcomes What do the staff and doctors actually do What will they say they do Much of visit is talking to service users and staff

Safeguarding Patients are protected from abuse, or the risk of abuse, and their human rights are respected and upheld Compliance is anticipated if the practice takes action to identify and prevent abuse from happening in a service responds appropriately when it suspects abuse has occurred or is at risk of occurring ensures that Government and local guidance is accessible to all staff and put into practice understands how diversity, beliefs and values of people who use services may influence the identification, prevention and response to safeguarding concerns protect others from the negative effect of any behaviour by people who use services

Claiming compliance Ensure staff have had safeguarding training appropriate to their role Take appropriate action to protect patients if any member of staff exploits a vulnerable adult or child Ensure patients can raise concerns and make complaints related to abuse Have a mechanism for patients to make comments and a publicised complaints procedure. Share relevant information with other providers, in accordance with local safeguarding procedures Comply with the Vetting and Barring Scheme

Documentation A safeguarding children (child protection) policy A safeguarding adults policy A patient information leaflet about abuse What patients should do if they have suspicions that another person has been abused What they might expect to happen under safeguarding procedures

At a visit… No good just having your policy document CQC is about demonstrating outcomes What do the staff and doctors do What will they say they do

Safety and suitability of premises Patients are treated in safe accessible surroundings that promote their wellbeing Premises should be safe and secure from risks created by premises design and layout Premises should be managed to reduce risks The key to this outcome is to recognise risks and manage them Where possible, make adjustments that are reasonably practical

Claiming compliance Patients, staff and others know they are protected against the risks of unsafe or unsuitable premises by: The design and layout of the premises being suitable for the activity Appropriate measures being in place to ensure the security of the premises The premises and any grounds being adequately maintained Compliance with any legal requirements relating to the premises Account is taken of any relevant design technical and operational standards When an issue cannot be resolved seek to manage the risks Displaying appropriate information (e.g. alternative practices, how to access support) Providing appropriate support to patients Adjusting how you use different parts of your premises

At a visit… No good just having your policy document CQC is about demonstrating outcomes Why did you claim compliance What do the staff and doctors do in practice What will they say they do

Table work I Registered managers Who should have the role in our practice Why What support is needed Who should manage the CQC account The registered manager Practice manager How do they get support

Table work II Each table has at least: One Essential Standard requiring compliance to be claimed at application One other Essential Standard Your tasks Make a record of why you are/are not compliant Write an action plan to achieve compliance Consider how you would ensure the reporting standards are met