A guide to CQC compliance for general practices | How can I pass a CQC inspection?
Inspections of GP practices are, of course, incredibly important. That also means they can be incredibly stressful, not least because of the vast amounts of documentation you are required to provide. We’ve developed this guide of the fundamentals to help you prepare for a successful inspection.
These inspections are carried out by the body known as the Care Quality Commission, also known by the acronym CQC. Read on for some guidance on their process of inspection, the kinds of things inspectors will be looking out for and what they expect you to provide as evidence either of improvement or continually maintained standards.
Contents
How often does CQC inspect GP practices?
It varies. It can be as frequent as every 6 months, but the practice’s rating will determine the time between inspections. If a practice is rated ‘inadequate’, the maximum time between visits is 6 months; for a practice that ‘requires improvement’ it is 1 year; for practices rated ‘good’ or ‘outstanding’ a maximum of 5 years can be left between inspections.
How long do I have to prepare for an inspection?
The CQC will carry out a formal regulatory review of your practice every year. This will involve using data and information from stakeholders like Healthwatch, for example, and a phone call with the practice itself. Using these factors, CQC will determine if there’s an urgent need to inspect the practice.
Assuming the CQC organises an inspection (either because they have been alerted to a deterioration in standards, or the maximum time in between inspections has elapsed) a call will be made to the practice giving them 14 days to prepare, and a letter will follow to confirm the date of inspection. In some instances, it can be unannounced, but it’s only when inspectors are responding to a certain, likely urgent, issue.
The CQC will make clear what they require from the practice, but there is a range of documentation that will take longer to prepare than the five days given to respond to the email. The ideal inspection preparation is fully integrated into the practice’s internal audit processes, so documentation and evidence can be easily produced in the weeks leading up to the inspection.
What will the CQC ask for?
In the CQC’s first letter, they may request a range of evidence that will be largely patient-focused. This could include:
An action plan addressing findings from patient surveys.
A summary of complaints made in the last 12 months, and the practice’s strategy to confront them.
A summary of adverse events in the last 12 months.
Evidence that two clinical audit cycles have taken place in the last 12 months.
Recruitment and training procedure policies.
The number of staff and roles.
A copy of the practice’s current statement of purpose.
All or some of this information will feed into their assessment of what exactly needs to be inspected at the practice.
What are the CQC monitoring questions for GP practices?
When it comes to the day of inspection, the CQC team will arrive with five questions, that they will look to answer when assessing the practice:
Is the service safe?
Is it effective?
Is it caring?
Is it responsive?
Is it well-led?
Inspectors will always inspect at least four of the CQC monitoring questions for GP practices, but will sometimes choose not to investigate care, especially if a general practice has previously been rated good or outstanding. However, if information acquired in the review has revealed uncertainty around a practice’s level of care, inspectors will explore all the key questions in a comprehensive inspection. This is rare, and comprehensive inspections are usually carried out when a service is being inspected for the first time.
What documentation needs to be prepared?
Inspectors will come prepared with key lines of enquiry, or KLOEs as they’re also known, that will allow them to consistently and fairly examine how well practice is upholding the values outlined in the CQCs five questions. For instance, a KLOE might involve assessing fire safety and protocol when asking, is the service safe? Below is a summary of the kinds of documents and evidence that will likely be required when the CQC is pursuing these lines of enquiry:
Is the service safe?
Health and safety policies, including risk assessments specific to the building you operate in.
Fire safety equipment documents.
Infection control risk assessments, especially those mitigating the risk posed by COVID-19.
Safeguarding risk assessments.
Safe staffing level assessments.
Is the service effective?
Healthcare records and patient need assessments.
Policies on mental capacity.
Staff training records and personnel files.
Strategies for working with specific demographics in the practice’s area. These typically face inequalities in healthcare.
Is the service caring?
Privacy policies that ensure dignity and respect for practice users.
Bullying and harassment policies.
Records for training on topics such as trans inclusion or equality and diversity.
Protocol on the interpreter service.
Is the service responsive?
Healthcare and treatment records.
Complaint records (much of this may have to be provided before an inspector’s arrival).
Data demonstrating average wait times and referrals.
Is the service well-led?
Mission statements and business plans that demonstrate a vision for the practice’s future.
Minutes of meetings conducted with staff and users on implementing service improvements.
Surveys of user groups and subsequent strategies that respond to complaint patterns.
Patient surveys that examine their care in relation to the six population groups.
Quality assurance audits.
A staff matrix that keeps track of training and ensures skills development.
Clear protocols for whistleblowing.
Making sure that the documentation for specific KLOEs are all in date and organised to a degree that allows the practice manager to easily locate them is the ideal position for a practice before an upcoming inspection.
This may seem like a mammoth task, but that’s where Crysp comes in. With our all-in-one compliance platform, you can organise all your health and safety documentation in one place. The platform provides you both with the essential risk assessments for your practice, and a means to build your own policy forms for staff training or capacity policies, for instance.
The platform will give you an overview of upcoming reviews, so you can easily keep on top of documentation for an inspection at any time in the year. And, you can share it with colleagues and stakeholders, so they can easily find the materials to prepare for the inspection too.
How can I practise for the CQC inspection?
A mock inspection. Besides preparing documentation, another important element of a CQC toolkit for GP practices is a dry run; one that uses a checklist mirroring the things observed by a real inspector. It could include a review of the tidiness of the areas in the practice on a given day, as well as other basics like fridge temperatures, emergency drugs and practice logs. Here is list of questions that a practice manager could ask in a mock inspection:
What is the location of the fire extinguisher, and is it in date?
Do staff know where the first aid kit is, and who is qualified to use it?
How effective is the comment box, if present?
Are there allocated isolation rooms and do they work?
Has the medical supplies cupboard been locked?
Is all the stock in date?
Is the patient participation group on display?
Mock inspections and subsequent meetings should be noted and have minutes taken in order to create more supporting evidence of the practice’s commitment to improvement.
Preparing the 30-minute presentation is another part of the preparation and requires a good deal of attention. This will usually take place at the start of the inspection and is a great opportunity to show improvement in the practice. This is not an exhaustive list, but the presentation should include:
The history and ethos of the practice.
How the practice operates in the context of its area and the demographics it caters to.
Reasons why the practice may appear as an outlier within the CQC’s Intelligent Monitoring (if applicable).
Policies that show it’s well-led (whistleblowing policies, responding to patient surveys etc.).
Information on access to appointments, such as telephone appointments, appointments with female and male clinicians.
Anonymous cases that demonstrate compliance with care and privacy standards, as well as examples of outstanding efforts made by staff.
How the practice works with other organisations.
A snapshot demonstrating a range of people’s opinions about the practice.
Evidence of completed audits and strategies to improve in areas where challenges have been identified.
How can I prepare staff?
Naturally, it’s beneficial to inform staff of the date of the inspection and introduce, or remind, them of the inspection process. It’s a good idea to make clear protocols or safety processes that were seemingly unclear or incomplete in the mock inspection. In addition, urge staff to review documents on health and safety as well as patient care.
For senior staff, pointing them towards the CQC monitoring questions for GP practices can be helpful. Encourage staff to think about examples of care and leadership that answer the questions in the framework, so they are prepared for interviews with inspectors, if they take place. Equally, it can be helpful to hire a locum on the day of inspection, so senior staff are free to be involved in inspections or the presentation. Check out the first person accounts from practice managers of inspections in this BMA report to gain a good sense of the process.
How can Crysp help?
As we mentioned, Crysp can provide a digital platform in which you can monitor your practice’s assessments and audit cycles, allowing you to keep on top of it all year round. This platform is not only a place to store all the documentation, but a place for staff to access the relevant protocols in preparation for an inspection. Our platform for GP practices is the perfect addition to your CQC toolkit!
Crysp also offers a consultancy service, that you can use to gain advice on the quality of your audits, and if you need specific advice on the most effective way to conduct a risk assessment, we’ll match you with a compliance advisor who has expertise in healthcare. Contact us now for an informal chat about health and safety in your GP practice, and we'll work with you to make sure you're covered!
And if you’re curious about how other service providers are inspected by the CQC, check out our guidance blogs for care homes, salons, dental practices and aesthetic clinics.
