Preparing for a CQC inspection can be a stressful and daunting task, but there are a number of basic rules that can make providers’ lives easier.
Preparations should not begin with a panicked response to receiving the Provider Information Return (PIR) – a good organisation will have processes in place that mean preparation is in fact ongoing throughout the year.
One of the key elements is having properly held and recorded files. Two important points are:
- Create physical files (copied to a document folder on your computer system for easy reprinting/updating) with up-to-date policies and procedures, service user feedback, letters from families, external assessments, third party feedback, etc. Ensure that all staff leads are aware of where these files are located. It is vital that this information is provided to CQC on request and, if not asked for during inspection, make sure this is provided to inspectors whether or not they ask. Review the contents of the file/s with set regularity to check it always has the most up to date documentation and complies with the most current service practice.
- There is discretion in relation to how providers choose to meet the regulations, but where providers choose a specific route for care and treatment (especially where this may be outside of 'standard' and/ or NICE guidelines) providers must record the process they went through to arrive at that decision and the clinical/ client base reasoning for these decisions. Recording this rationale in a clear format and making this easily accessible for inspectors gives them the insight they need into provider practices and makes Factual Accuracy Comments (FAC) challenges easier if CQC later criticise choices made and/ or a lack of rationale for such choices.
However, it is about much more than paperwork. There are a number of other factors that inspectors will be looking for evidence of, which we will briefly outline in turn.
Transparent and evidence-based governance structure
Inspectors want to see evidence that the organisation is well-led. So, you must be able to demonstrate a clear leadership culture within the service. Where there are senior management meetings, these must be minuted and any actions and dissemination to frontline staff must be clearly evidenced.
Furthermore, it is important that:
- Communication of the governance ethos runs throughout the organisation
- The ethos is understood and shared with service users and their families as well as staff
- Family meetings should reflect this transparency, both in terms of complaints handling and sharing the service’s future plans
CQC expects providers to carry out regular internal auditing of quality – not simply waiting for CQC inspections but actively checking your own practices and procedures.
Regular audits of all aspects of care/ treatment/ policies/ governance must be put in place, and you need to get the frequency of these audits right: some audit timescales are prescribed by law (H&S), some have best practice, and some are service/ environment dependent.
There is no point in creating unrealistic frequency of audits within a policy and then explaining to CQC that you simply couldn't fit it in because of work pressures. CQC expects you to decide upon a frequency of audits that:
- Protects service users
- Maintains quality care
- Reflect the realities of the service
Crucially, audits must not simply be completed but also reflected upon, with an audit trail that demonstrates what action should be taken as a result and then demonstrating that it has been taken.
An engaged workforce is another absolutely critical element. You must be able to show that staff not only know the policies and procedures of the service, but they understand the rationale for them and can evidence that they are being complied with. It is vital to ensure that your staff understand not simply what the service does and why, but how to explain this using CQC language. This is not about parroting catchphrases, but about ensuring that staff know what it is that CQC test against and how that applies to what they do with service users on a daily basis.
For example, your activities timetable may appear to only have lists of prescribed activities, but in fact service users are asked daily what they would prefer and bespoke models are created. Staff need to be able to explain this so that CQC are then able to understand that what looks like a one-size-fits-all policy is in fact a bespoke service focusing on person-centred care (a focus of CQC at the moment).
Other key aspects are:
- Demonstrating that staff are listened to (through minuted team meetings, anonymous feedback surveys, whistleblowing policies, etc)
- Having evidence of sufficient general and specific training
- Evidence of adequate supervisions, that are recorded and maintained
If your organisation is doing of all of these things, then you will be putting yourself in the best position possible ahead of an inspection.
However, you may also want to consider obtaining a third party perspective. At Bevan Brittan, we regularly work with specialist consultants to complete a mock inspection and provide an independent assessment. This helps avoid the blinkered line of sight that can come from living with your own policies and procedures and brings an objective, outside view.
Written by Jodie Sinclair, Partner, and Nicole Ridgwell, Associate.
Originally published in Healthcare Markets Magazine in November 2018.