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

New CQC Regulations The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – published November 2014: http://www.legislation.gov.uk/uksi/2014/2936/pdfs/uksi_20142936_en.pdf The new regulations cover: Fit and Proper Person (FPP) requirements Duty of Candour New 11 Fundamental Standards

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

CQC Intelligence Monitoring Registration Intelligence Monitoring Inspection Rating

CQC Operating Model

CQC Rating Scale Outstanding Good Requires Improvement Inadequate

The new inspection process Key Document: How CQC Regulates: NHS GP practices and GP out-of-hour services; provider handbook (October 2014) http://www.cqc.org.uk/sites/default/files/20141008_gp_practices_and_ooh_provider_handbook_main_final.pdf

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

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)

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

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

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

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

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

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?

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

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

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!

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

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

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