1

CQC’s new approach to inspecting GP practices & what this means for you

Linda Hirst Primary Medical Services and Integrated Care Directorate.

2

About CQC

Our purpose • We make sure health and social care services provide people with safe,

effective, compassionate, high-quality care and we encourage care services to improve.

Our role • We monitor, inspect and regulate services to make sure they meet fundamental

standards of quality and safety and we publish what we find, including performance ratings to help people choose care.

Our principles • We put people who use services at the centre of our work. • We are independent, rigorous, fair and consistent. • We have an open and accessible culture. • We work in partnership across the health and social care system. • We are committed to being a high performing organisation and apply the same

standards of continuous improvement to ourselves that we expect of others. • We promote equality, diversity and human rights.

• Types of Inspection• Scheduled, Responsive, Themed

3

Our new approach and why we changed

• We changed in response to the findings of public enquiries. We consulted widely about what our new approach should look like. We have radically restructured. We now have three directorates

• We have completely changed the way we monitor, regulate and inspect

• We use intelligent monitoring to decide when, where and what to inspect, including listening better to people’s experiences of care

• When we inspect we will answer the following questions

• Is the service safe?

• Is the service effective?

• Is the service caring?

• Is the service responsive?

• Is the service well-led?

4

Our new approach

• We will use the information we gather on inspections to help us rate the quality of the service and we will publish this rating to enable people using services to make informed decisions about health and social care services. We will publish ratings on GP services from October 2014 continuing until April 2016.

• The ratings are:

• Outstanding

• Good

• Requires Improvement

• Inadequate

• Services receiving a rating of requires improvement or inadequate will result in a regulatory response and more frequent inspections. They will not all be announced.

• New legislation and Regulations to underpin our approach are at an advanced stage.

5

Our new approach

6

How we inspect

• Inspections of a number of practices carried out in a CCG area over a 2-4 week period. We will visit each CCG, probably every six months, inspecting a quarter of practices in that area each time we visit. We will meet with Area Teams and CCGs before and after inspections of practices in the area.

• We will gather intelligence about the practice, the health information profile of the CCG and will look at intelligence from QOF data (if available), patient survey data, comments and ratings on NHS Choices, intelligence from NHS England. We will look at the practice website (if available). We will take account of direct concerns and complaints received from patients, information from whistleblowers, information from stakeholders and professional bodies (GMC, NMC, HPC). We will use information from listening events and from other directorates to identify any information of good practice or areas of concern. We will use this information to target and plan our inspections.

• We will announce our inspections in advance and will be in touch to explain our inspection, who will be part of the inspection team, the process we will follow and to answer any initial questions you may have.

7

How we inspect

• When their planning is completed and signed off by their inspection manager, our inspectors will supply you with a proposed timetable for the day and a poster to display in the practice. They may provide you with a list of documents and information they will wish to see in advance to enable you to prepare. They will negotiate an arrival time (usually ahead of practice opening to enable questions.

• We will have a specialist inspection team which will comprise one or more inspectors from CQC, a GP advisor, a practice manager advisor and on occasion an expert by experience or a pharmacist inspector (if you are a dispensing practice).

• The inspection team will always

• Speak to patients – it is helpful (if possible) to have a private room to facilitate this.

• Observe interactions between practice staff and patients – this will NOT involve sitting in on patient consultations unless there is a very good reason for this and the patient agrees.

• Speak to a range of practice staff (all designations) – think in advance how you can facilitate this.

8

How we inspect

• Inspect the practice in respect of; cleanliness and infection control, safety of premises, safety of equipment, confidentiality of patient records, safety of medicines and prescribing practices. Think about these areas and be prepared for questions, to be asked for audits and action plans.

• We may look at patient records if there is a specific need to do this – this will usually be because we have highlighted a risk to patients. We will ask our GP advisor or an inspector will do this. We will never ask an expert by experience to look at patient records. We are developing guidance on this issue.

• We will ask you to arrange for us to meet/have a telephone discussion with members of your PPG (if you have one). If not be prepared to answer questions about how your practice obtains the views of patients and uses these to arrive at a decision about the quality of patient care and service.

• If your practice has more than one branch we may visit other branches.

• We will ask about your clinical audits. Clinical Audit is defined by HQIP and endorsed by NICE as: ‘a quality improvement process that seeks to improve patient care and outcomes through systematic review of care and the implementation of change.’

9

Clinical audit

• Clinical Audit is a process or cycle of events that help ensure patients receive the right care and the right treatment. This is done by measuring the care and services provided against evidence base standards, changes are implemented to narrow the gap between existing practice and what is known to be best practice. Ideally, a clinical audit is a continuous cycle that is continuously measured with improvements made after each cycle.

 

10

How we inspect

We will always look at services at a location (GP practice) level through the lens of six patient groups. For every NHS GP practice we will look at the quality of care for the following key patient groups: • Older people (over 75s)

• People with long term conditions

• Mothers, babies, children & young people

• Working age population and those recently retired

• People in vulnerable circumstances who may have poor access to primary care (Eg homeless people, people with drug or alcohol dependency, sex workers, travellers, people with learning disabilities. This is not an exhaustive list)

• People experiencing a mental health problem

• Think about what your service provides and elements of outstanding practice and be prepared to let us know about this.

11

How we inspect

• Expect inspections to last the whole day or in large practices or where there are complex issues possibly two days.

• The inspection team will provide headline feedback at the end of each inspection. They will not be able to tell you your quality rating.

• If there is any evidence of immediate risk to patients this will be brought to your attention on the day.

• You will receive a draft report and you have 10 days to comment on factual accuracy only. You will receive a response if you make factual accuracy comments with the final report. The report will then be published

12

Top Tips for Inspections

• We will still inspect against the current Health and Social Care Act 2008 and Regulated Activities Regulations 2010 until the Care Bill 2014 is enacted. The current Guidance About Compliance will help you to interpret the Regulations. Be aware of and have read these key documents and think about how your service ensures these are being met

• Know your service and tell the inspection team about it, providing evidence of this. We must corroborate our findings. Tell us what you do well and also what needs to improve and crucially what you are doing to improve it. Remember it is your legal obligation to identify, assess and manage risks. Think about how you manage risks at a patient and practice level.

• Ensure your staff relax and are honest. We do not expect perfection, but we expect you to strive for improvement and to ensure patients are protected from harm and receive a good quality, responsive and caring service. We will ask a lot of questions, some will be quite searching, we are looking at the impact of what you do on patient care and welfare.

• If we set requirements, make sure you send in SMART action plans within the timescales set. It is an offence not to!

• Make sure the registration of your service is right!

13

Links to useful information

Our website

www.cqc.org.uk

Notifications

http://www.cqc.org.uk/content/notifications-gp-providers

Making changes to your registration

http://www.cqc.org.uk/content/application-form-finder About our inspections http://www.cqc.org.uk/content/how-we-inspect-gps-and-primary-medical-services-when-they%E2%80%99re-registered

About our new approachhttp://www.cqc.org.uk/sites/default/files/documents/20131211_-_gp_signposting_statement_-_final.pdf

14

References

• Consultation on provider handbook

http://www.cqc.org.uk/sites/default/files/20140409_provider_handbook_consultation_gp_practices_final_for_web.pdf

Guidance about compliance

http://www.cqc.org.uk/sites/default/files/documents/guidance_about_compliance_summary.pdf

Health and Social Care Act 2008 Regulated Activities Regulations 2010

http://www.cqc.org.uk/sites/default/files/documents/health_and_social_care_act_2008_regulated_activities.pdf

15

Thank you for listening

Any questions?