The first Care Quality Commission inspections have now taken place and so we can finally put paid to a lot of speculation and mythology about what these would involve. The rumour machine will not yet grind to a halt and some might say that some of the inspections raise more questions – perhaps some we have not thought of asking before! However CODE has collated information and feedback from its members about the inspections they have had, and the purpose of this article is to look at what has actually happened and more specifically to look at the facts of what these tell us about the way practices who have not yet had inspections should prepare.
The truth is out there in more ways than one; some practices seem still to be unaware that the main findings of CQC inspections are available for public consumption on their website. This means that any of your patients (current or potential) can check up on what has been said about you. Many dentists are taking the view that that is all the more reason to make sure that when your turn comes you have done everything you can to ensure that your practice is the picture of compliance health.
A key message is don't underestimate the depth into which the inspectors will go, and expect probing in areas where you declared non-compliance on your registration form. One practice has reported a six hour inspection to probe two outcomes but not all inspections take this long and some focus on more outcomes than this. It seems most practices are being given some notice and several have reported a 48 hour notice period.
If you are the registered manager, expect an interview of some two to two-and-a-half hours. Managers have been asked for meeting minutes particularly where this was an audit or training meeting. Be ready to show personnel files. Inspectors have checked the content and paid special attention to the contract, records of training and appraisal or performance review records. If you do not have these, expect to give a good and compelling reason why not.
Make sure that all your staff who have contact with children and vulnerable adults have enhanced CRB disclosures. Keep a note of the date, certificate number and your decision based on the information from the certificate on their personnel files.
In at least one practice all the team members had a conversation of some 20 minutes with the inspector providing confirmation of the answers that had been given by the manager – in effect checking that what the manager said happened actually did. Inspectors have also asked staff about the way they are managed and supported.
We have heard that some of the inspectors have a good understanding of infection control issues. One checked the dates of all the materials in all surgeries, asked to look at the autoclaves and asked all team members to demonstrate the decontamination process starting from scrubbing instruments. Inspectors have also checked that all instruments were bagged and labelled. Your staff can also expect to be asked what they would do in the event of a medical emergency and in one case all staff were asked about the emergency drugs kit. Be prepared to provide good answers to questions. One inspector spotted loose instruments in a drawer in a treatment room. Although the reason for them being there was justified (apparently to the inspector's satisfaction) this appeared on the draft report.
Staff will also be asked about patient care; specifically in one instance staff were asked to explain the process of what they should do if they suspected that an adult was being abused. Some inspectors have asked a great deal about this and the recent bad press concerning care homes may perhaps be part of the reason for this. Some inspectors have also focused on dealing with patients with disabilities and one practice was asked whether the receptionists asked new patients if they needed any assistance when they visited the practice.
Clinical records will also be scrutinised. It is not unusual for a staff member to be asked to get the relevant PPE for a dental check up, and dentists report being asked for a sample of records of different groups of patients, for example, new patients, nervous patients, National Health Service patients, and those having had extensive treatments. It would be worth considering which ones you would pull up if asked for the same information. If you are in a mixed practice stand by too for tricky questions about the differences in the level of service NHS and private patients receive, and make sure that you are all agreed in your answer.
Logs are an important feature of inspections as CODE forecast. More than one inspector requested the daily autoclave logs, logs for ultrasonic cleaner and domestic cleaning audit so make sure that you have these.
Don't forget that patients are also part of the process. One inspector asked for the contact details of 20 patients from different groups and the consent for her to telephone them to gain feedback about the practice. Inspectors are interested in currency and so one of those had to be a recent attendee. Again it is worth thinking through who you would choose.
Having seen some draft CQC reports it is worth remembering that these contain information from a number of areas, including those statements you made at registration, evidence observed and checked by the inspector, and indeed patient feedback. The reports we have seen contain some very positive information about the practice and patients who have been contacted or spoken to whilst the inspector was at the practice are quoted (anonymously). Some of these comments that we have seen are highly complimentary and would be an asset on any report on view in the public domain on the website. Bear in mind also that patients also have the ability to provide feedback direct to the CQC on the website about your practice and it remains to be seen how far, if at all, this is taken into consideration in the next round of inspections – and at least one practice has been told to expect another inspection in a year.
Some general points to remember:
- Your inspector may not have a clinical background although some do, and you may not get the same inspector the next time round.
- Your inspection could well take less time if you have all of your documentation in place and it is carefully cross-referenced. One practice which used the CODE CGMS kit reported that this made things much easier during their inspection. Being organised in this way will save the inspectors time and, by association, you too.
- Inspectors seem open to answering questions on how to improve and what to do from this point so make the most of their time in the practice and ask what they would expect to see next time.
If there is one primary thing to take from all of this it is – make sure that you have good procedures in place and that people are following them. If any of these experiences of others this gives you cause for concern remember CODE is there to help, and we are currently offering pre-inspection reviews through CODE Assure service, comprising a one day audit for £595 plus travel expenses of up to £100.