So, what does this mean for your CQC inspections? As you will be aware, since April this year, the CQC has been inspecting dental practices in a different way. This is to reflect our profession’s needs and to ensure that the inspections are doing what they are designed to do, which is to guarantee that all healthcare providers are fully compliant with the regulations. The great news is that the inspections will be less frequent, but when they do happen they will be far more expert and carried out by inspectors who really know the profession inside and out. The inspector will be with you for the entire day checking every fundamental standard rather than just a select few. It won’t be as simple as asking to look at your Regulation 11 Consent, for example, the inspector will be working using a set of five key lines of enquiry (KLOEs) with prompts for each one. Instead you will be asked if and how you obtain valid consent, so it is important to ensure that your whole team knows the answers to questions like these.
Who cares?
All of the KLOEs and prompts are readily available to all practitioners to read and understand in the Primary Care Dental Services Provider Handbook, which can be downloaded fro the CQC website at www.cqc.org.uk/sites/default/files/20150326_dental_care_provider_handbook.pdf
I would strongly advise reading this as it contains vital information that is essential to understanding the inspections. One of the KLOEs that the inspectors will be using is “Is the service caring?”, and it is important to analyse what the CQC class as caring in order to know how to be compliant in this area.
According to the CQC Handbook: “By caring, we mean that staff involve and treat people with compassion, kindness, dignity and respect,” and the regulations that especially apply to this KLOE are:
- Consent – regulation 11
- Dignity and respect – regulation 10, and
- Person-centred care – regulation 9
These are the prompts that inspectors will use to judge whether your practice provides a caring service:
- Are people treated with kindness, dignity, respect and compassion while they receive care and treatment?
- How are patients and those close to them involved as partners in their care?
- Do people who use services, and those close to them, receive the support they need to cope emotionally with their care and treatment?
How do you care?
What is important is that you show the CQC, in their terms, that you provide a caring service. To help with this CODE provides a range of templates to help you train your team, which include policies on consent, patient care, patient experience, equality and diversity.
Under this KLOE, it would seem that the data collected before your inspection will play a big part. The CQC will be looking for reports that people are treated with dignity and respect and that the practice supports the privacy of patients. Through “intelligent monitoring”, the CQC will collect information about your practice prior to inspection. This data will come from local Healthwatch and local overview and scrutiny committees. The CQC may also request that you display a sign letting people know about the upcoming inspection and requesting them to share their experiences of the service you provide; it may also supply you with a questionnaire card for patients to complete and post into a separate box. The inspector will be using this information for additional evidence. Be aware of other data resources that may be used, like online review sites and social media. If you have received a negative comment, it is important to ensure that you respond to it in a timely manner offering to resolve any concerns that the patient may have; this can help to show your caring attitude. Try not to worry about one bad comment; a flood of positive comments will outweigh it as long as you have responded correctly.
The inspector may also speak to the patients in your practice on the day of the inspection. He or she will be seeking to find out whether patients feel as though the clinical staff listened to them and responded to any distress or pain quickly and appropriately. Although it may seem almost obvious that the dental team will act in a caring manner, it may be worth while carrying out specific training in these areas, perhaps through team role play, in order to ensure that all members of staff understand the importance of these skills and attributes.
Another point to note is that inspectors will want to see your clinical records and they will know what to look out for. These can show that all treatments are fully explained, including the cost of treatment, with patients given all viable options and adequate time to make the right decision for their own circumstances. Although you may know that your own clinical records are up to scratch, it is well worth checking that those of other staff (associates, for example) are also well maintained prior to inspection.
Privacy and confidentiality will also be considered as part of this KLOE so you must ensure that your clinical records are secure and that all staff have signed up to date confidentiality agreements in place.
There must also be policies in place for patients who may require extra support with regards to consent. The Mental Capacity Act is one of the CQC’s hot topics and it is highly likely that you will be asked about your policies on this. CODE members have access to a consent policy template as well as guidance on valid consent for them to implement in their practices. iComply members are prompted to carry out a consent review and discuss it at the practice meeting.
Each member of your staff needs to be up to date with these in order to explain or demonstrate the practice procedure under circumstances where you believe the patient cannot make an informed decision for themselves.
Above and beyond
You may feel as though it is obvious that you provide a caring service, simply because it’s part of the profession you are in. However, it is important to understand the CQC’s definition of caring and ensure that you – and your whole team – are working towards displaying this. It is likely that you will go above and beyond these levels of care, but you must have the correct policies and procedures in place to satisfy the requirements of the regulations and, therefore, the inspections.
Easy points for inspection day
• Ensure the overall tidiness and cleanliness of the practice
• Make sure the complaints procedure is visible to patients
• Ensure your fee list is readily available
• Check that you have a comments and suggestions box in the patient waiting area or reception
• Place up-to-date patient information leaflets in patient areas