1. CQC Workshop New Inspection Process How to prepare for a successful outcome Vicky Ferlia Director of GP Support, Londonwide LMCs Renos Pittarides Managing Partner, Richford Gate Medical Practice

2. New CQC Regulations
The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – published November 2014:
The new regulations cover:
Fit and Proper Person (FPP) requirements
Duty of Candour
New 11 Fundamental Standards

3. From the old to the new standards - coming into force 1 April 2015
16 Safety & Quality Standards
11 Fundamental Standards
Care and welfare of service users
Assessing and monitoring the quality of service provision
Safeguarding service users from abuse
Cleanliness and infection control
Management of medicines
Meeting nutritional needs
Safety and suitability of premises
Safety and suitability of equipment
Respecting and involving service users
Consent to care and treatment
Complaints
Records
Requirements relating to workers
Staffing
Supporting workers
Cooperating with other providers
Person-centred care
Dignity and respect
Need for consent
Safe care and treatment
Safeguarding service users from abuse*
Meeting nutritional needs
Cleanliness, safety and suitability of premises and equipment
Receiving and acting on complaints
Good governance
Staffing
Fit and proper persons employed
Fit and proper person requirement for directors
Duty of candour

4. CQC Intelligence Monitoring
Registration
Intelligence Monitoring
Inspection
Rating

5. CQC Operating Model

6. CQC Rating Scale
Outstanding
Good
Requires Improvement
Inadequate

7. The new inspection process
Key Document:
How CQC Regulates: NHS GP practices and GP out-of-hour services; provider handbook (October 2014)

8. 5 Key Questions 5 key questions:
All GP practices and OOH to be inspected by April 2016
5 key questions:
Safe - people are protected from abuse and avoidable harm
Effective - people’s care, treatment and support achieves good outcomes, promotes a good quality of life and is based on the best available evidence
Caring - staff involve and treat people with compassion, kindness, dignity and respect
Responsive - services are organised so that they meet people’s needs
Well-led - the leadership, management and governance of the organisation assures the delivery of high-quality person-centred care, supports learning and innovation, and promotes an open and fair culture

9. 6 Population Groups
CQC assessments are focusing on 6 population groups:
Older people
People with long term conditions
Families, children and young people
Working age people (including those recently retired and students)
People whose circumstances may make them vulnerable
People experiencing poor mental health (including people with dementia)

10. Key Lines of Enquiry (KLOEs)
Inspection teams use standard set of KLOEs, that directly relate to the 5 key Qs
Each KLOE is accompanied by a number of questions, called prompts
The info gathered before and during the inspection will determine which prompt questions will be used by the inspectors
Described in Appendix B of provider handbook

11. Preparing Premises & Equipment
The relevant regulations
And
Detailed guidance on premises, equipment, carpets, curtains, defibrillators, oxygen, hand hygiene…
is available in your resource pack

12. Preparing your Policies
Review and amend any policies that are out of date
Have paper copies available on the day for CQC inspectors
Ensure all staff know where policies are stored electronically and manually
Have a system to record that staff have read them
Make sure your policies are a true reflection of the way you work – CQC inspectors will compare staff answers to what is written in your policies. It is not a test but a way of accessing if staff are aware of procedures relevant to their role
Have a clear and auditable system for updating policies and communicating updates to all staff

13. Preparing your Staff (1)
The inspecting team will interview members of staff
Make sure staff are aware of the visit and that they may be asked questions
If possible know staff availability in case a member of staff phones in sick
Carry out ‘mock’ inspections/staff interviews in-house or with a neighbouring practice

14. Preparing your Staff (2)
Issues to discuss including what evidence the practice can provide:
Sharing/understanding policies
Recognition and report possible child/elderly protection issues
Helping people with LD/mental health problems
Team meetings

15. Preparing your Staff (3)
Ensure staff are aware of the Key Lines of Enquiry (KLOEs)
Example Safety 1
Do staff understand their responsibilities to raise concerns, to record safety incidents, concerns and near misses, and to report them internally and externally where appropriate?

16. Preparing your GPs (1)
As soon as you know when the visit is, identify the lead GP
In depth interview by the clinician on the inspection team with the GP
Discussion areas will include:
Clinical governance
Training especially child protection/ safe guarding vulnerable adults, BLS
Communication, this may include seeing care plans eg AU DES
Clinical meetings
Audits
Medicines management
How staff learning needs are identified
Team working e.g. all staff involved in assessing/planning/delivering care
Mental capacity assessment
End of Life care
Appointments, availability, run on time etc
Leadership role

17. Preparing your GPs (2) EVIDENCE
The inspecting team will wish to see evidence to back up what they are being told

18. Critically appraising and challenging your draft report
You have two weeks to make comments on the factual accuracy of your draft report
Despite being the regulator, CQC is not an expert on all the legal, contractual etc requirements on GPs
Good practice recommendations are often mistaken as requirements
You CAN influence your final report as long as you know what and how to challenge
Challenging inappropriate, unfounded, biased, ill informed etc findings is extremely important – your report will be in the public domain and a negative CQC rating could seriously damage your practice
Do NOT be intimidated by CQC!

19. Case study – Wimbledon Village Surgery
Inspection took place in May 2014
Inspection lasted 11 hours – inspector ‘too tired’ to give feedback at the end
Draft report was issued 6 months later
Report commented on data seen by inspectors but not the practice
Report commented negatively on documentation that existed but was not available on the day
No appeal process against observations, opinions, conclusions, assumptions, or omissions

20. What the practice did
Sent an open letter to Prof Field and Nigel Sparrow after the inspection
Raised 41 challenges of factual accuracy in their draft report
Invited CQC to meet with them to discuss findings
Sent second open letter to CQC after draft report was issued, following CQC’s failure to meet with the practice
Revised report issued by CQC
Outcome: most of the practice’s challenges were accepted in the final report

21. THANK YOU! gpsupport@lmc.org.uk
Any queries, problems, adverse findings in your CQC report etc, please contact us at: