As you will know by now, the CQC has given its entire inspection system an overhaul, but will things really be that different on inspection day? To put it simply, yes! The CQC have employed new inspectors who have been specially trained to really get under the skin of your practice. They know what they’re looking for and they will also be accompanied by a dentist; meaning that you will have two pairs of expert eyes arriving on inspection day. Not only that, they will be in your practice for a full day checking whether you are compliant with respect to every single regulation – not just a few as with the old-style system.
Under the new-style CQC inspections your practice will be scrutinised with regards to five key lines of enquiry (KLOEs), which are what the inspectors will use as prompts to ensure they are checking every area of compliance. Each KLOE will relate to specific fundamental standards and inspectors will use these in order to make consistent judgements across providers.
Every dental practice will have different ways of demonstrating how they meet the requirements and the CQC has provided a comprehensive handbook that includes a number of extremely useful examples to help you understand what type of things the inspectors will look for in your practice. If you haven’t already done so, it is well worth reading the CQC Provider Handbook for primary dental care services. It isn’t particularly long and it contains excellent explanations of each of the KLOEs and what an inspector will be asking themselves during the inspection. It is important to be aware that the examples of evidence listed are simply a guide rather than an exhaustive checklist, although it can be helpful preparation. To download the latest version simply visit www.cqc.org.uk/sites/default/files/20150430_dental_care_provider_handbook.pdf
Under the microscope
One of the KLOEs is ‘Is the service well-led?’ As with each of the KLOEs, there are a number of regulations from the Health and Social Care Act 2008 that specifically relate to determining whether a practice is well led, or not. These are:
- Complaints (Regulation 16)
- Good Governance (Regulation 17)
- Staffing (Regulation 18)
- Safeguarding service users from abuse and improper treatment (Regulation 13)
- Safe care and treatment (Regulation 12)
- It also includes the two new fundamental standards: duty of candour (Regulation 20) and fit and proper persons (both directors Regulation 5 and employees Regulation 19).
According to the CQC, “By well led, we mean that 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.” As we can see, this refers to the management and governance of the team and the practice, as well as the provision of care for patients as individuals, while promoting an ethos of fairness and openness. In a nutshell, there’s quite a lot covered under this KLOE.
Let’s be clear, under this KLOE inspectors will be looking at staff records and job responsibilities, so be sure that all of these are up to date and that each team member understands the full scope of their role in the practice. All staff should be supported with regards to meeting their professional requirements, such as training and CPD hours, there should be valid policies in place that refer to this, and staff must be aware of them. Under the new-style inspections, the inspectors will speak to members of your team and they will also be able to access your clinical records – which should be complete, legible, accurate and secure.
The fit and proper persons: directors requirement is a new standard to ensure that directors (or those in a senior role) are fit and proper for the role they are appointed to. This means that they must have appropriate skills and qualifications for running a dental practice, but they must also have a caring and compassionate nature.
Transparency is key
There should be systems in place to support communication about the quality and safety of the services you provide. This means that you need to have robust feedback and complaints systems in place as well as honesty and transparency. The duty of candour is another new standard and is designed to ensure that providers have an open and honest culture, especially in relation to complaints and when things go wrong. For detailed advice CODE members and iComply application users can download the relevant modules on how to meet CQC requirements.
A joint vision
Under this KLOE, the CQC inspector will look for how you use feedback and quality assurance to drive continuous improvement and whether or not there is an effective approach for managing and responding to issues of quality and safety. This means that a practice not only has to have a governance system in place, with clearly defined responsibilities, but the CQC is looking closely at how well this system is operating and if it is not effective questions will be raised on how ‘well led’ the practice is. Inspectors will want to see the ways in which you collect
information and how you use it to improve the patient experience. This will be another area where interviews with your team will be important as the inspectors will be looking to see how information is shared to aid continuous learning and development within the practice.
As part of the new regime, knowledgeable inspectors will not only be checking that you have completed all of your risk assessments and audits within the required time frame, but also how accurately they have been completed. Feedback is vital under this KLOE, as inspectors will again be looking at the processes the practice has in place to actively seek the views of those who use the service. They will be looking for evidence of this and the decisions that are made in respect of it. Staff involvement is also key and inspectors will be checking that your team feel engaged and involved with the planning and delivery of the service.
Reports on the CQC website from the new inspections are showing that they are also looking at whether appropriate follow-up actions have been created as a result of risk assessments and audits and that these actions have been dealt with in a reasonable time frame.
Prepared?
There’s no doubt that it’s a daunting scenario but there are solutions available to help give you peace of mind. For example, CODE is able to offer practice health checks and mock inspections. These will be able to tell you whether you are meeting all of the regulations or not and they will provide an action plan highlighting any areas that require
improvement.
So, will you really be ready when an inspector calls?
Top tip
Review your last risk assessments and audits: were they completed accurately and have you dealt with any outstanding actions? If you do have anything remaining to deal with, would you be able to justify to an inspector why it has not been completed? If the answer is no, ensure that you carry out your follow-ups as a matter of urgency.