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Ensuring Compliance – CQC Inspections

Laura Paton Solicitor (Qualified in Scotland), Ridouts

Inspections are at the heart of CQC’s model for ensuring compliance and will remain so as indicated in in their strategy for 2016 to 2021.

Inspections can be a nerve wracking experience, but they don’t have to be.  They are your opportunity to demonstrate compliance and show off how good your service really is.

The key to a good inspection outcome is preparation. Providers should use the time from the pre-inspection down to the publication of the final report to ensure that what is published is an accurate and fair representation of the service.

What to Expect

According to CQC guidance, the size and make up of the inspection team will be tailored to each service and what CQC need to inspect. In many cases this will mean a minimum of one inspector and an Expert by Experience. The inspection team could also include a specialist advisor and/or a pharmacist inspector.

CQC has indicated in its strategy for 2016 to 2021 that “inspections will be the most resource intensive where the risk to people using services is greatest. Therefore, inspecting an inadequate service will normally be a longer inspection with a bigger team, compared to when we return to a good service where the information available suggests the rating remains accurate.”

The inspection team will carry out a range of assessment activities, including reviewing records, policies and procedures. They will observe care and they will speak to people who use the service, their families, staff and professionals. They will assess all of the key questions (Safe, Effective, Caring, Responsive, and Well Led) using their published KLOE’s and Prompts and will rate each key question in line with their ratings characteristics.

To ensure the best outcome we recommend the following top tips for preparation:

Before the Inspection

  • Utilise your Provider Information Return (or online Provider Information Collection) to the full. Keep it up to date and use it to highlight evidence of innovation, research, improvement and sustainability.
  • Make sure staff are aware of your whistleblowing policy and how to report concerns to the Provider directly to avoid any ‘surprise’ complaints directly to CQC.
  • Challenge your own systems as part of Quality Assurance and audit to check for weaknesses against the CQC Key Lines of Enquiry and prompts. Consider getting an independent pair of eyes like a consultant, to come in and assess compliance with the Fundamental Standards.
  • Gather feedback from service users and family, review it and act upon it.
  • Ensure staff are familiar with what to expect from a CQC inspection. Explain that they may be interviewed or observed as part of the process and reassure them to be confident about this. Typical areas of questioning are around safeguarding and staff understanding of the principles of the Mental Capacity Act.

During the Inspection

  • Ask questions, offer assistance and request feedback throughout to avoid surprises.Provide outstanding information and ensure you address any immediate compliance issues that arise during the inspection promptly
  • At the feedback session, make notes, ask questions, request evidence to support CQC’s findings

After the Inspection

  • Supply any additional evidence that CQC request promptly and comprehensively Also, ask for clarification about issues that you are unclear about
  • Respond in detail to the draft inspection report –you only have 10 working days to submit factual accuracy comments. Doublecheck CQC has the date right for submitting Factual Accuracy Comments – it is often wrong on the cover letter. Consider obtaining expert legal advice to assist in challenging ratings through the factual accuracy process
  • Remember to display your ratings in your service and on your website – it is an offence not to do so. If you are dissatisfied with the outcome of the inspection and wish to challenge your ratings

 

At Ridouts we have extensive experience in assisting providers with Factual Accuracy Responses. If you have received a draft report you are unhappy with do not hesitate to contact us for assistance.

 

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