CQC Inspection Bombshells

  

Requests for a re-inspection

Summary of CQC Response

  • Providers cannot request a re-inspection
  • You will be stuck with negative ratings for many years
  • CQC is focused on finding NEW services at risks
  • Public will not be aware of your improvements
  • Even the CQC view ratings as low value for "need to assess"

  

PLAIN ENGLISH SUMMARY OF THE CQC RESPONSE

CONTEXT
How can a Provider improve their rating after receiving a negative rating
(request for reinspection)

CQC RESPONSE
“There is no formal process for providers to request an assessment to change their rating, nor are there plans to introduce such a process.”

CQC POLICY ON REINSPECTION
“We will no longer use the rating of a service as the main driver. when deciding when we next need to assess”
Any review is totally at the discretion of the CQC and the next assessment will be planned, or when new “concerning information” is received.

CQC RISK BASED TARGETTING
“….we generally focus our resources on services where there is risk.”

• CQC is focused mainly on finding new services at risk
• Once a Provider is identified and rated as high-risk at the inspection, there is no mechanism for ongoing monitoring until the risk is eliminated; and there is no mechanism to motivate or even allow improvement and be reinspected
• The CQC place minimal value on their own risk rating as they “…will no longer use the rating of a service as the main driver…. when we next need to assess”

THE EFFECT ON PROVIDERS
Regardless of the improvements made, there is no pathway to remove the stigma of a negative rating, which must be displayed prominently on web sites, and can remain unchanged for up to 10 years.
At the date of this request, there are almost 8,000 Providers stuck with negative ratings which are up to 5 years out of date.

In effect, these Providers are trapped in a system where a negative rating becomes a permanent stain, almost impossible to remove.

FUTURE PLANS
The CQC clarifies that as the Single Assessment Framework has been declared not fit for purpose in a review by Dr Penelope Dash, their plans and targets have been suspended and regular reviews will not start until the model is fixed and is fully implemented. It is unclear when that will be.

Changes to the framework are underway, the CQC states “Work is therefore currently underway to improve how we use our new regulatory approach”

 Link to the Freedom of Information Request  
   

Case Study: Instantly in Special Measures

How these providers failed at everything all at once

We looked at two particular inspection failures, one had as many resources as you could wish for and another being your usual smaller provider with one Manager.

Both had comprehensive policies; an online document management system; and generally provided good care.

Things ran smoothly. Everything looked fine.

At The inspection

It all looked good on paper, so the CQC Rating came as a shocker.

case study two providers

 

Senior Management is shocked!

Information isn’t to hand, processes are not always followed, there are gaps in the system, things are not done properly.

2024 Inspections will be even more challenging as the focus shifts to “Feedback” which most systems are not designed for

This rating will stay on their web site until the next inspection. That could be the next 5 Years, unless you ask for a reinspection.

Lessons learnt

  • It is not just about having the best policies or more human resources
  • 99% of the inspection is about continuous compliance
  • Don’t let the inspector be the first to find your weaknesses

The solution

CQC inspections are based on your performance over the last 12-24 months. By the time an inspection is announced, it is already too late to prepare.

The registered Manager is central to an inspection. The uncomfortable truth is that the Registered Manager delegated everything, did not monitor, and took their eye off the ball.

You must be inspection-ready anytime, and your system should tell you this at the press of a button.

Clinical Audits

Apps for a robust Clinical Audits System.

A Clinical Audit System should comprise two elements:-

  1. An effective Policy and Governance
  2. A consistent process that records each audit

Our system will enable you to achieve these with two applications in tandem:-

  1. Risk Assessment Channel

A comprehensive Risk Assessment based on the guide by NICE; CHI,RCN, University of Leicester.

This is a living document that combines Risk Assessment, Governance, and Policy Statement in one. The initial “one-off” review should take no more than 10 minutes to complete, and the Dashboard will automatically generate a Risk Matrix together with a  risk rated Governance and Policy Document, incorporating National Best Practice as published by NICE.

Regular reviews should take no more than 5 minutes at most, best be done as a team exercise as part of the individual clinical audits. This automatically achieves group training and development; enables discussion of improvement strategies; and acts as a team refresher and briefing, to demonstrate leadership and Well-Led criterion.

  1. Processes Channel: Clinical Audits Record

The process for conducting regular Clinical Audits is to be found in the “Quality Audits” section in the Processes Channel.

This App covers the required principles of Topic Selection; Criteria; Standards; Outcomes; and Reflection, ensuring your approach meets the stringent NICE standards. A printable checklist allows offline planning, training and general discussion of the principles before the formal meeting.

Recording the process and outcomes takes just minutes, and the  Dashboard will automatically generate your log of audits with a detailed record of your risk rated decision making.

Benefits:-

The ready-made processes take no more than a few minutes to record, and ensure that we follow a stringent quality process mapped directly to the highest standards.

What you will achieve is:-

  • A record of adherence to National Standards
  • Consistent and structured approach to every Clinical Audit
  • Dashboards to show Risk Analytics

IPC Risk Assessed in ONE Day

IPC Risk Assessed in ONE Day

98% NHS England audit score

1.                The Challenge:

I joined as the interim PM of this Practice and one of my first urgent tasks was to complete the IPC audit for an imminent NHS England IPC Audit.

This was a bigger challenge than I had anticipated as there was nothing to work from, the last IPC Risk Assessment was done some 4 years ago and could not be located. There were limited regular checks, and as with many smaller Practices, there were limited staff and resources.

The Lead Nurse was faced with the daunting prospect of the 45-page NHS IPC Audit, which would have taken 3 to 6 weeks to implement on her own, with no other resource that would allow her to meet the robust requirements in such a short space of time and the inspection was due in 2 weeks.

The challenge was two-fold: Doing an IPC Risk Assessment to National Standards in a short time frame, identifying and fixing any potential issues before the auditors arrived. The only viable option seemed to be contracting an independent commercial audit.

2.                NHSE Audits:

NHSE inspectors take a constructive approach in getting practices compliant.
However, a low score will likely trigger a CQC inspection as the IPC team is duty-bound to notify the CQC.

3.                Solution:

By happenstance, we found that X-Genics, our Compliance System provider, was testing a prototype IPC Audit tool based directly on the NHS Toolkit and international best practice and were looking for volunteers to field test it before launch. This system was part of the digital automation bid project, we had collaborated on and had already implemented this bespoke automation software solution for general CQC Compliance and IIF Reporting.

4.                How we did it

The process turned out to be both simpler and faster than we had expected.

How the system works:-

  1. The National Standards are broken down into bite sized mini-Apps.
  2. Each App has an integrated mini checklist(s) to easily manage individual IPC areas.
  3. Each checklist is delegated to different staff, spreading the workload across the practice.
  4. Results are collated, risk evaluated and summarised into the App.
  5. Automatic Dashboards generate an Action Planner and Risk Matrix
  6. Action Points are addressed, and the Apps updated.
  7. Checklists are reused daily/weekly/monthly to achieve continuous compliance.
  8. The process of evaluation and summarising into the App is repeated through the year.

We distributed the user-friendly checklists to our staff, outlining specific tasks for hazard review. Each staff member received a checklist, and they were tasked with assessing and reporting on identified hazards, and staff were encouraged to fix minor issues on the spot. The nursing team and practice manager took charge of conducting reviews in key and high-risk areas. We added an element of fun by offering chocolates as rewards for timely completion and team achievements.

After completing the assessments, the checklists were collected the following day, and entered into the mini-apps. The software generated a user-friendly visual plan, with our risk mitigation steps, and our action plan for any outstanding action points.

Our strategy focused on starting with low-risk items that were more easily manageable and within our immediate control. Having achieved these "easy wins" and gaining experience, we progressed to focusing resources on higher risk areas. Identifying at an early stage, areas that required external assistance. For instance, we identified that the original door handles in a converted residential property were not easily wipeable, necessitating replacement and scheduled this in as an action point.

5.                Completion:

This approach created an efficient workflow and allowed us to tackle potential risks in a systematic manner, prioritising actions to achieve maximum impact with minimum effort.

There was zero training needed. The entire IPC Risk Assessment was completed in one day, leaving sufficient time to address issues for remedial action.

6.                Outcome:

98% score achieved at the NHS England audit two weeks after our risk assessment.
We achieved well over 100% return on investment compared to external contractors, on this App alone, and have started using others such as Fire Risk Assessment. We have taken full control of IPC, and this has now become continuous compliance instead of an annual exercise.

Going forward, the checklists are now used as our regular reviews, and results used to update the Apps. In addition, we rotate the staff and checklists, so staff learn about a different area every month, in effect a continuous training regime by “learning on the job”.

All staff feel empowered, engaged and enthused with their new responsibilities, a total culture change for the Practice, and a reduced workload for the Manager and Lead Nurse. In effect, our IPC runs automatically and autonomously thanks to our motivated staff.

7.                Improvements:

  1. We are IPC inspection ready at all times
  2. Professional compliance reports at the press of a button
  3. Saved the cost of external contractors
  4. Continuous Risk Assessments carried out every month at no extra cost
  5. A positive IPC Culture
  6. Reduced management workload
  7. Formal training sessions largely replaced by training on the job
  8. Staff teach each other when uncertain

8.                Credits:

Author: Shabana Dehlavi           Provider type: GP Practice         Date of study: February 2024

The system supplier is X-Genics via their CQC focused web site everythingCQC.com.
The Audit and Risk Assessment Channel includes risk assessments for Infection Control and Fire Risk; with COSHH, Display and Screen Equipment and Safeguarding currently in the pipeline.