When disgruntled staff make false accusations

Case Studies

Using our system as part of your defence in a CQC investigation Case Study: False claims by disgr

Using our system as part of your defence in a CQC investigation

Case Study: False claims by disgruntled staff

Date: August 2025

Account by: Practice Manager

Location: Manchester

The CQC Complaint

Several disgruntled ex-employees got together to file “whistleblowing” complaint against the practice. The allegations included equity of access; failings in admin and governance; insufficient staff; stress at work; bullying and harassment; freedom to speak up …… and the kitchen sink !

We had no idea what evidence had been submitted to support the complaint.

We had four days to respond.
Failure to provide assurance would trigger a same-day unannounced visit.

How We Prepared

Preparation extended well beyond documents.
Reception and Admin staff focused on patient communication protocols, clinicians reviewed compliance logs, and managers checked evidence folders and were ready with an action plan.
Clear communication ensured that everyone understood their responsibilities if inspectors arrived without notice.

How We Responded

We acknowledged shortcomings where appropriate and presented clear action plans to address any gaps.
We countered inaccurate claims with a robust defence supported by actual evidence.
We showed our best in class “inspection-ready” system, incorporating a full annual compliance plan, and pointed the CQC to our suppliers web site

The Outcome

The CQC accepted our defence and were assured that we had a robust Quality Management System in place.

The case was closed and all action suspended.

What Saved the Day

The ability to compile a convincing defence in a professional manner is critical. Having dealt with inspectors over many years, the first port of call was to connect with the inspector to establish a working relationship. Familiarity with all types of systems from Ardens to TeamNet, and from Practice Index, QCS and FPM, made evidence gathering that much easier.

For Governance side, just 3 months ago we purchased a Quality Standards System that is fast becoming a National Standard. We explained this system to the CQC, and they checked out our supplier site.

With virtually no preparation, we were able to assure the Inspector that: -

We had an ISO 9001:2015 “inspection-ready anytime” system, incorporating a full annual compliance plan
It was a recognised Governance system to demonstrate HSCA and CQC Guidance compliance
We had an “Interview-ready” staff handbook, including Appraisals, personal development; competency and knowledge; critical policies
The system created a culture of self-responsibility and engagement where staff monitored their own competency; trained each other; and organised their own workshops

Key Takeaways: When dealing with a potential investigation

Demonstrate you are Well-Led and well managed; show that this was just an anomaly
Demonstrate that you have a robust Governance System; show how you operate in practice
Prepare your systems early; It's too late to start when they knock on the door

Product used:

Quality Standards Manual: A structured approach to being inspection-ready anytime

Staff Passports: A personal Staff Development handbook for every member of staff, containing Appraisals, CPD record; Best Practice Knowledge; Key Policies. Creates a culture of self-responsibility and teamwork.

How often do CQC related regulations change

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When it comes to compliance, many practices feel under pressure to keep updating their polic

When it comes to compliance, many practices feel under pressure to keep updating their policy documents year after year. But the reality is very different: regulations hardly change.

The Truth About Policy "Updates"

Most so-called "updates" are minor tweaks—small changes to wording, layout, or grammar. Rarely do they involve substantive legal changes.

We analysed 10 years of legislation (2012–2023) and found:

Out of 398 new laws, just 17 affected providers.
That averages only 1 or 2 meaningful changes per year.
In 2023, there were no relevant new laws at all.

Key Legislative Changes Since 2012

Here are the substantive changes that actually matter for providers:

Legislation	Year	Relevance
Health and Care Act	2022	All Providers
Approved Premises (Substance Testing) Act	2022	Substance Abuse
Down Syndrome Act	2022	All Providers
Botulinum Toxin and Cosmetic Fillers (Children) Act	2021	All Providers
Coronavirus Act	2020	All Providers
Mental Capacity (Amendment) Act	2019	All Providers
Organ Donation (Deemed Consent) Act	2019	Hospitals
Health & Social Care (National Data Guardian) Act	2018	All Providers
Mental Health Units (Use of Force) Act	2018	Hospitals
Assaults on Emergency Workers Act	2018	Ambulance
Children and Social Work Act	2017	Adult Social Care
Immigration Act	2016	All Providers
NHS (Charitable Trusts Etc) Act	2016	Hospitals
Health Service Commissioner for England (Complaint Handling) Act	2015	All Providers
Health and Social Care (Safety and Quality) Act	2015	All Providers
Care Act	2014	All Providers
Immigration Act	2014	All Providers
Mental Health (Approval Functions) Act	2012	All Providers

That's it. Fewer than 20 laws in a decade have made a real difference to provider compliance obligations.

What Suppliers Won't Tell You About Costs

The compliance market is big business. Providers are often sold more than they need. Here's what's typically on offer:

What's Available

Downloadable packages – around £300 or less, promising 500+ policies, procedures, letters, and templates.
Online systems – £1,000–£2,000 per year, offering over 1,000 pages of guidance, with features like staff activity logs.

The Hidden Costs

Time to read every policy: Between one and three months of solid work (most never attempt it).
Staff training/testing via online systems: Adds administrative load and ongoing management time.
Briefing and testing staff knowledge: For a small organisation, this can equate to £15,000 in annual costs.

Saving Time and Money

Here's the bottom line:

Suppliers have little incentive to tell you the truth. If they admitted you only need 50 core policies, and that legislation changes maybe once a year, their model collapses.
You do not need a policy for every occasion. A well-written standard policy, applied with common sense, usually covers most scenarios.
Use policy packages selectively. If you're buying a large library, treat it as a reference resource—not a manual that must all be implemented.

Key Takeaway

Regulations are relatively stable, and the real compliance burden is often overstated. Instead of drowning in hundreds of documents, invest in a concise set of core policies, keep an eye on genuine legal changes, and focus on training staff to apply good judgement.

In other words: compliance is about people, not paperwork.

Would you like me to combine this with the previous blog (on number of policies) into a longer guide-style article, or keep them as two separate, more focused posts?

How many policies do you need for CQC

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This depends on the size of your organisation and the purpose of your policies.This is what yo

This depends on the size of your organisation and the purpose of your policies.
This is what you should aim to have for a typical organisation with less that 50 staff:-

CQC Policies	20 to 30
HR	5 to 10
Health & Safety	5 to 10
Admin	5 to 10

For larger organisations, the numbers might go up by say 20% due to the complexities of dealing with stricter and more centralised systems.

Minimise the number of policies

Focus on key policies and get them right
A common sense approach to safety will cover most unusual situations
It is better to invest time in developing staff and instilling common sense
Do not overwhelm staff with paperwork to cover every eventuality.

CQC says they're not that interested

Is it about policies?

"Absolutely not. We are much less interested in policies and protocols than in knowing what care is like for your patients, whether staff know what to do about things like child protection, and so on. Good practices shouldn't need to do anything they aren't already doing."

Professor David Haslam, National Clinical Adviser to the Care Quality Commission
(Interview in Healthcare Leader News May 2012)

"We won't normally spend a great deal of time reading policy or procedure documents, unless we need to look at them to substantiate other evidence or what staff or patients have told us about their experiences."

James Hedges, media officer at the CQC (statement to MDDUS May 2013)

This is where the CQC focus their inspections:-

Experiences people have when they receive care and the impact the care has on their health and well-being.
Talking to patients, their families and their carers.
Looking at records or speaking with staff and how they reach their judgements.

British Medical Association says don't bother with large numbers

Question: Is 'CQC' all about policies and protocols?

What the BMA says:

"We believe that most providers will already be compliant with the essential standards" and "CQC registration should not involve the development of large numbers of new policies and protocols."

Extracts from the BMA CQC Registration guidance for GPs.