It’s nearly a year and a half since the Care Quality Commission (CQC) changed the way in which it regulates and inspects practices. As a regional support manager for Practice Plan, one of the things I am most often asked whilst visiting my customers is how best to prepare for a CQC inspection.
Preparation has always and will always be the key, as will ensuring that the whole team understands what they need to do and is fully involved in the practice’s protocols. Apolline has always been our preferred provider of all matters relating to regulatory compliance, so I asked Dr Pat Langley from Apolline to share some tips. Her first insight focuses on understanding the changes and the key facts, and the focus of the new fundamental standards.
The key changes
- There are now two types of inspection – ‘comprehensive’ and ‘focused’. Comprehensive inspections will seek to establish whether the practice provides care that is safe, effective, caring and responsive, and whether it is well led. Practices will usually be given two weeks’ notice prior to an inspection and the actual inspection will take one day. Focused inspections concentrate only on areas indicated by the particular information that triggered the inspection and can be announced or unannounced depending on why it is taking place
- 10% of practices will have comprehensive inspections in 2015/16 – selected either randomly or on risk-based criteria
- At the beginning of an inspection, practices are asked to discuss any areas of the regulations that they are not currently complying with and what they are doing about it. In addition, practices are asked for any areas of ‘notable’ practise, meaning any areas in which they exceed the regulations
- There has been some shift in emphasis with the fundamental standards, with some new regulations relating to ‘fit and proper persons’ being employed and a new regulation called Duty of Candour
- Some of the regulations, such as the need for consent, the requirement to provide safe care and treatment and to have an effective complaints handling process, contain prosecutable clauses
- There is now a need to be able to demonstrate you have an effective governance system and that your practice is well led
- Patient records will continue to be scrutinised
- In short, Pat advises that since the CQC focuses on the outcome for patients, you should do the same.
Duty of Candour
This in truth has alarmed people a little, but Pat tells me that all it means is that when things go wrong you should tell the truth and apologise to the patient. The team at Apolline always advise practices that recording, discussing and acting on significant incidents demonstrates that you are doing everything you can to avoid repeat adverse occurrences.
This makes sense from a business perspective, as it can be costly when things go wrong because it takes up a lot of time in addition to creating avoidable stress and complaints. Reducing ‘things that go wrong’ should also make your practice safer, less prone to complaints and more efficient.
What does ‘outcome for patients’ mean?
Pat told me that ‘outcome for patients’ is what happens in your practice as a result of implementing all your policies and protocols. Outcome is made up of ‘structure’ (your pieces of kit) and ‘process’ (your protocols and what happens in your practice).
Traditionally, inspections of dental practices only looked at structure and process but that is all different with CQC inspections because they are focused on outcome for patients, ie, what happens for patients as a result. An example would be a situation in which a patient had a medical emergency. Your ‘structure’ is your emergency drugs and your equipment. Your ‘process’ is your policies, your training and your protocols. The outcome is what happens if a patient collapses in your practice. You need the right structure and processes in place to make sure you get the right outcome for the patient.
Pat says that the question the CQC inspector will most likely ask is ‘what would happen (or what did happen) if a patient suffered a medical emergency in your practice?’.
If you have any questions in relation to the changes or this guidance, contact Apolline on 0800 193 1033 or by email at [email protected]