Harrow All Practice Meeting 16 September 2015 New CQC inspection process: How to prepare for a successful outcome Jane Betts Director of Primary Care Strategy Nora Breen Manager, GP Support Services
New CQC Regulations The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 published November 2014: http://www.legislation.gov.uk/uksi/2014/29 36/pdfs/uksi_20142936_en.pdf The new regulations cover: Fit and Proper Person (FPP) requirements Duty of Candour New 13 Fundamental Standards
From the old to the new standards - came into force 1 st April 2015 16 Safety & Quality Standards 13 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
CQC Intelligence Monitoring Registration Intelligence Monitoring Inspection Rating
CQC Operating Model
CQC Rating Scale Outstanding Good Requires Improvement Inadequate
CQC Rating Methodology There is no room for adequate, satisfactory, or compliant if you are not rated Good, you automatically Require Improvement Overall ratings are not calculated on statistical principles; e.g. two Good + three RI = RI overall Not all 5 Key domains are equal Safe and Well-Led affect the overall rating more than the other three An RI or Inadequate rating in the Safe and/or Well-Led domains, means this rating will be carried through ALL six population groups, regardless of any positive findings in relation to those population groups
Harrow CQC visits 8 practices inspected so far Outstanding Good Requires improvement Inadequate 0 6 1 1 0% 75% 12.5% 12.5% Practices Safe Effective Caring Responsive Well - Led Overall Practice 1 Practice 2 Practice 3 Practice 4 Practice 5 Practice 6 Practice 7 Practice 8 Key Outstanding Good Requires Improvement Inadequate
Main areas of non-compliance (1) No DBS checks for staff acting as chaperones No patient consent policy. Inadequate systems to monitor and improve quality and identify risk Not involving patients in decisions about their care
Main areas of non-compliance (2) Lack of complete clinical audit cycles Lack of regular infection control audits Lack of legionella risk assessments No business continuity plan No staff training on infection control, acting as a chaperone, Mental Capacity Act, Safeguarding
Main areas of non compliance (3) No evidence of PPG contribution No promotion of PPG No signage directing patients around the practice No policy or log for monitoring drugs fridge temperatures No annual staff appraisals No record of staff meetings
How does CQC build Evidence towards Rating Ongoing local information Information from people, carers and staff Complaints Information from stakeholders Local and national data Patient surveys Clinical quality and activity (QOF/HES) Contextual information (pop/public health data) Pre-inspection information gathering People who use the service National datasets CQC records Other stakeholders (AT, CCG, Healthwatch) The Provider On-site inspection Observation of care Information from people, carers and staff Care environment and facilities Record and document review
Key Documents on the new CQC inspection process (1) 1. How CQC Regulates: NHS GP practices and GP out-of-hour services; provider handbook (updated 27 March 2015) http://www.cqc.org.uk/sites/default/files/2015032 7_gp_practices_provider_handbook_march_15_ update_01.pdf 2. Provider handbook appendices ( March 2015) http://www.cqc.org.uk/sites/default/files/2015032 7_GP_practices_provider_handbook_appendice s_march_15_update.pdf
Key Documents on the new CQC inspection process (2) GPC guidance on CQC inspections: http://bma.org.uk/practical-support-atwork/gp-practices/service-provision/carequality-commission/cqc-inspection Londonwide LMCs guidance on CQC inspections: http:///visageimages/guidanc e/2015/londonwide%20lmcs%20cqc%20 Guidance.pdf
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
6 Population Groups CQC assessments are focusing on six 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)
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 Practices should familiarise themselves with Appendix B of provider handbook: http://www.cqc.org.uk/sites/default/files/20150327_gp_practi ces_provider_handbook_appendices_march_15_update.pdf
Info required prior to the visit (1) Provider handbook lists the following: Practice s Statement of Purpose Action plan addressing patient survey results Complaints of last 12 mths, actions & learning Serious incidents of last 12 mths, as above Two completed clinical audits in last 12 mths Number of WTE staff by role Recruitment policies Staff training records
Other key documentation to prepare (1) Infection control audits Health & Safety, Fire Safety audits & PAT testing registers Business continuity plan HR staff files, employment policies Staff induction policies, locum policy/pack Staff training matrix, appraisal/cpd Safeguarding and chaperoning policies Equipment calibration reports Palliative care registers
Other key documentation to prepare (2) Service information (e.g. key population demographics, statement of purpose/ practice leaflet, treatment options, how to make comments and complaints etc) Care planning & assessment protocols, meeting equality and diversity needs Medicines management policies including storage, stock management, handling, recording and disposal; prescribing policies and protocols Medication audits/error reporting and action plans, checks on emergency drugs, stock control policies
Preparing your Policies Review and amend any policies that are out of date Have either paper copies available on the day for CQC inspectors and/or a dedicated electronic folder 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
Preparing your Staff (1) Inspecting team will interview staff members Ensure staff are aware of visit and that they may be asked questions Know staff availability, prepare for staff absence and front desk cover. If needed, book locums to free up partners on the day Carry out mock inspections/staff interviews in-house or with a neighbouring practice
Preparing your Staff (2) Have dedicated meetings with staff to ensure they are aware of what they may be asked examples: Sharing/understanding policies, e.g. process for handling path lab results and hospital correspondence Appointment system Child & vulnerable adults safeguarding processes and training Chaperone policy Helping people with LD/mental health problems Team meetings
Preparing your Staff (3) Ensure staff familiarise themselves with the CQC GP Provider Handbook and 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?
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 Leadership role 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
Preparing your GPs (2) Ensure partners understand their leadership role and take responsibility for their areas of the CQC inspection Have dedicated meetings with the partners to prepare well in advance Evidence, evidence, evidence! The inspecting team will wish to see evidence to back up what they are being told
Preparing your patients Put notices in waiting area of CQC visit Inform your PPG and arrange for PPG chair or a member to attend on day of visit Ensure you have a robust complaints policy in place that is well publicised to patients Read CQC s Guide for Working Together http://www.cqc.org.uk/sites/default/files/docu ments/20130509_cqc_guide_for_ppgs_final.p df
CQC s enforcement powers & Special Measures regime CQC has enormous powers Backed up by the H&SCA 2012 with political support across the board Warning & enforcement notices Suspension & cancellation of registration Special measures regime if Inadequate rating on ONE key question or population group
Critically appraising and challenging your draft report Two weeks for practices to make factual accuracy comments Despite being the regulator, CQC is not an expert on all the legal, contractual etc requirements on GPs Good practice is often mistaken as a requirement You can influence your final report as long as you use factual evidence to support your corrections Challenging inappropriate, unfounded, biased, ill informed etc findings in a factually based and professional manner is extremely important your report will be in the public domain and a negative CQC rating could seriously damage your practice Know what is expected of you so you can challenge appropriately, but also - - be prepared to accept and reflect on genuine criticism. Do not let emotion guide your responses. Use facts.
Further essential reading: Nigel Sparrow s myth busters on CQC website: http://www.cqc.org.uk/content/mythbustersand-tips-gps-and-out-hours-services DBS checks: http://www.cqc.org.uk/sites/default/files/disclo sure%20and%20barring%20service%20chec ks%20guidance%20100646.pdf Infection control: The Health and Social Care Act 2008, Code of Practice on the prevention and control of infections and related guidance
THANK YOU! Any queries, problems, adverse rating in your CQC report, help with your action plan etc, please contact us at: gpsupport@lmc.org.uk