You should be aware by now that the CQC has altered the way it carries out inspections of dental practices, which will now be based around five key lines of enquiry (KLOEs), rather than a selection of outcomes.
I expect that most CQC inspections will be carried out by one person but the big difference this time is that they will be in your practice for the full day and they will be checking all standards, rather than a selected few. You will be given two weeks’ notice of an inspection and you will have plenty of communication with the lead inspector and inspection planner to help you prepare and understand what to expect. Data will also be collected before the inspection, which will be more thorough than it has been and will help the inspector to build a bigger, and fairer, picture of your service.
This data will come from discussions with local Healthwatch, local area teams and local overview and scrutiny committees about your service. 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.
Is the service effective?
By effective, the CQC means “that people’s care, treatment and support achieves good outcomes, promotes a good quality of life and is based on the best available evidence”. In order to determine whether a service is effective, the CQC inspector will consider these regulations from the new Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – fundamental standards:
- Person-centred care (Regulation 9)
- Duty of candour (Regulation 20)
- Consent (Regulation 11)
- Staffing (Regulation 18)
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 during the inspection. It is important to be aware that the questions listed are simply a guide rather than an exhaustive checklist, although it can be helpful preparation. To download a copy visit www.cqc.org.uk/file/170317
Person-centred care
Under these new style inspections, it seems that the CQC inspector will want to see your clinical records. These should allow you to demonstrate that individual patient needs have been considered, and should show that an up-to-date medical history has been taken and that the purpose of the appointment has been fully explained to the patient. Make sure that all clinical notes in your practice fully record the patient assessment and outline the explanation given to the patient of all treatment options available to them. Each member of staff should be aware
of this but it would be wise to double check the notes your associates are making.
You also need to provide relevant information and support to patients to help them understand their care. Good
examples of this would be patient leaflets that outline different treatments in easy to digest language, or similar
information on your website. Having open communication pathways – such as telephone and email – that allow patients to ask questions and discuss concerns about their treatment is also advisable. Clearly providing this information in your waiting and reception area alongside your complaints procedure, fee list, and comments and suggestions box are all visual and easy wins for your practice during an inspection.
Duty of candour
This is one of two new standards and it seems to be cropping up in most of the KLOEs. With this in mind, I would anticipate that this is something you really need to be up to speed on. Duty of candour is designed to ensure that
providers have an open and honest culture, especially in relation to complaints and when things go wrong. Patients must be given support, truthful information and an apology.
For detailed advice on how to meet Duty of candour requirements, CODE members can download the module Duty of Candour (M 291), and a Duty of Candour Policy (M233-DOC) from the Code website. iComply application members will be prompted to do this and also to train their team at a scheduled practice meeting.
Consent
Staff must be able to demonstrate that they understand that consent is ongoing and can be withdrawn at any time. There must also be policies in place for patients who may require extra support in this area. 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. 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.
Staffing
You and your staff must be fully trained and fit to carry out the job you are all employed to do and an inspector will want to see evidence of this. Of course, continuing professional development (CPD) will show what has been learnt and courses that have been undertaken, so all records need to be up to date and available to view.
It may also be worthwhile demonstrating the support the practice gives the team for this, which may be through funding learning and development or by allowing staff to have time off (whether paid or unpaid) in order to keep their skills up to date. An inspector may ask any member of the team how the practice supports them with this so it is important that everyone is aware of the policy you have in place.
Remember
CQC inspections are not designed to ‘catch you out’; they are there to ensure dental providers offer a certain level of quality to patients. You are encouraged to discuss areas of good practice and outline what you are doing to improve areas that aren’t quite so good. It is always wise to follow best practice where possible and inspectors will look out and ask for any evidence of this. Working towards best practice will help to ensure you are working above and beyond the level of care an inspector is looking for.
Top tip
Be aware of other data resources that may be used, like online review sites and social media. Keep an eye on your public image and make sure all comments made by patients (whether good or bad) have been properly responded to; even if it’s just a simple thank you for some positive feedback.