It is perhaps unfortunate that because the public sector financial year runs from April 1, to March 31, all new initiatives seem to start on All Fools Day. Yet April 1 is the date when dental practices in England need to show the levels of compliance they have claimed in their registration documents with the CQC, and that date is, in reality, only a few short weeks away. Many of you will already have had contact with the CQC after getting in your registration documents, but what can you be doing now?
Much has changed, a little has been clarified, and sadly in some cases more has become more opaque since I began writing about CQC issues last summer. But there are some core elements which remain the same and it is helpful to focus on these when preparing for the April 1 deadline. In the debate about some of the minutiae of the requirements and the mountains of paperwork, we need to remember some key points.
Your quality management system, the clinical governance system you have in place in your practice, will be a starting point for demonstrating many of the outcomes. But demonstrating these outcomes will mean more than showing a regulator the paperwork, it will also mean your staff need to understand what they should be doing. If you haven't already done so now would be an excellent opportunity to review your current meeting arrangements and making sure you are communicating regularly with staff about policies and procedures, what they mean for them, and the findings from audits and actions to be taken to improve standards.
There is though a time for reviewing and a time for planning. The reviewing process, albeit a frustrating one for some, was one most practices went through before Christmas. Now is the time for action and with only weeks to go to April 1, you need to make sure you have set out action plans on your CQC registration documents, that you have a clear timetable with sensible deadlines for implementing those action plans and that you are actually getting on with them.
In addition to your action plans, here are a few other points to be thinking about now:
- although this may seem prosaic advice, get your paperwork in order and make sure you know where all your evidence such as audits and patient survey results actually is. An efficient filing system will pay dividends later in terms of saved time and effort.
- check the evidence you have to show that you are compliant with CQC requirements remains sufficient, relevant and current from April 1 and is not starting to look out of date by then. For example, if you consider you have good evidence that you are compliant in the area of suitability of management because your registered manager undertook relevant management updating in 2010, it is worthwhile checking that some is in the pipeline for 2011 as well, and that their management personal development plan is up-to-date and forward looking.
On the same lines, are your audits up-to-date? Many people I met on our CODE road shows last year told me they would be undertaking patient surveys to gain patient feedback early this year. They should be starting them now if they have not done so already.
With all of this, make sure this is not simply a paperwork exercise undertaken by one person; it will be essential the staff have some understanding of the purpose of the CQC requirements and regular team meetings are generally important for this. Your staff need to be, and remain, up to speed with what CQC registration is all about; it is helpful for them to know the six key areas in which the CQC are interested (involvement and information; personalised care, treatment and support; safeguarding and safety; suitability of staffing; quality and management; and suitability of management) and how these affect them, their relationship with patients and their role and responsibilities in the practice.
The team meetings I mentioned earlier will also help to maintain the momentum that you are going to need. If getting to registration has been a long haul for some, bear in mind that some practices may not receive a visit from the regulators for many months and possibly not until 2012, so keeping people on track and focused in the months to come will be essential. The CQC requirements are not just another initiative to be forgotten about after a few months; what they mean for the practice like good clinical governance needs to be embedded into the practice way of life. CQC registration is not just for Christmas, it's for life.
CODE will remain at the forefront of helping dentists to meet and continue to meet the CQC requirements and will also be gathering information from visits and inspections; we will pass this on to our members so they know what to expect and how to prepare effectively for a visit from the regulators.
Our popular Clinical Governance Made Simple kit continues to be updated as we receive more information about the CQC's requirements and how these are being interpreted; we recognise many need help in making sure the right things get done, and making sure systems and procedures have the sustainability that the CQC will be looking for. We also offer an additional service called Code Assure that provides compliance hand-holding support, regular compliance health-checks and even Code Accreditation service. Code is here to help – up to April 1, and beyond.