The Care Quality Commission (CQC) regulates health and social care services in England. Thus, a CQC inspection visit could be quite challenging for practice and care home managers.
In this article, we highlight the key elements of a CQC inspection visit, how to prepare for a visit and how to best present your practice or care home. This article is not about hacks or “cheating the system”. It is about making the right preparations and presenting the information that your inspectors need in the best way possible in order to get the best results for your quality improvement efforts.
- Pre-inspection preparations
- What you should expect during an inspection visit
- Post-inspection guide
You can also learn about CQC standards and KLOE here.
Pre-Inspection Preparations – What to Expect and Do Before a CQC Inspection
The CQC inspections are generally unannounced, as they aim to get the most accurate picture of how the service functions on a day to day basis. This means that you have to be prepared at almost any time.
The CQC will be carrying out one of three types of inspection:
- A responsive inspection, intended to respond to concerns that have already been identified.
- A themed inspection, looking at issues or concerns that have been identified at a national level.
- A scheduled inspection, planned in advance and carried out at any time without warning.
The first step to preparing for an inspection is to use either a compliance assessment tool (one is available on the CQC website) or your own system to assess and monitor how you comply with the KLOEs and standards set by the CQC. Make sure that on your systems you consistently demonstrate this compliance – for example you should maintain a clear record of complaints, when they were submitted, and how you made adaptations to the service provided in response.
The CQC has access to a wide array of information about each individual service it will be inspecting. This includes the information collected during your last report, any information communicated to them by you (notifications), complaints submitted, safeguarding alerts, and any other monitoring reports.
They will also retrieve any necessary information obtained by shareholders and the public. The information gathered from this research will determine which areas require the most thorough inspection – there may be certain standards more relevant to your service, or there may be reports made that cast doubt over your ability to meet standards in a particular area.
Other experts may accompany an inspector to the evaluation, including a professional advisor, or an expert by experience (a service user with experience and an in-depth understanding of what is required in your service).
It is vital that you have plans for what will happen during the inspection. These plans should include identifying individuals that would be particularly useful for an inspector to talk to, selecting an area which can be used for any individual interviews or discussions, and most importantly, planning how your usual services can still be provided while the inspection is in progress.
There must also be a plan outlining how the registered manager of the practice would be contacted if they are not on duty while the inspection is being carried out. They may need to organise phone calls to members of staff or service users on behalf of the CQC to gather insight into their experiences.
In summary, you should carry out all of these preparations:
- Making staff aware of how the inspection works.
- Being ready to produce any documentation necessary for the inspection.
- Organising care plans carefully, with a contents page so it is easy to navigate.
- Maintaining a folder for staff containing any information they need to know.
- Keeping your records up to date.
During a CQC Inspection – What to Expect and Do
One of the key methods a CQC inspector will use to carry out their evaluation is observing and talking to individuals who are service users, carers, or staff. Ultimately, human experiences will demonstrate the quality of care the strongest. They will likely watch how different routine services are carried out, such as the lunch service provided, or how staff interact with the individuals under their care for routine check-up procedures.
Staff of all levels will be spoken to in order to gain the fullest picture of how they work collaboratively and individually. The CQC expects staff members to have a good understanding of what their role is, and how their work provides the best possible outcome for individuals under their care.
They will likely ask questions such as:
“How would you act if you had a safeguarding concern?”
“How do you take responsibility for the quality of care that you are giving?”
A CQC investigator will usually also carry out pathway tracking. This is where they follow a particular individual’s route through the service and ask them about their experiences and views on the care they have received. This is considered to be a vital part of their investigation process. It allows them to document a sample of people’s experiences, whether they choose to shadow a new patient, an older patient who has been in the service for longer, or the patient with the most complex needs.
Depending on the type of investigation being carried out, there may be particular documents, areas, or patients that they would like to view. For example, they may ask to see your training records, your methods of storing medication, or the support plans that you have in place.
You must ensure that records are detailed and accurate, and make sure that they display how you are ensuring the best possible outcomes for the individuals under your care. It is also important to make sure you have access to the necessary documents at all times, in case of an inspection. If you are unable to produce the documents for what they consider to be a valid reason, you will have a maximum 48 hours to produce them for inspection. This could potentially damage your report.
The CQC will be looking for any evidence of non-compliance. They will do this through checking your records (with a focus on various areas such as lack of information about the medicines being used, or care plans not being reviewed on a regular basis) and will always check their findings against what they observe being carried out in the health or social care centre.
For example, if they see issues in your policy on storing medication, they will check how the medication is stored across the establishment. Similarly, if they observe that staff are not interacting enough with the individuals under their care, they will check policies and records to identify whether this is where the problem lies and confirm the scale of the issue.
Check with the inspector that they have all the information they require and have spoken to all of the individuals they needed to speak to.
Post-Inspection Guide – What to Expect and do After a CQC Inspection
After your inspection, you will receive an inspection report from the CQC, usually within 10 working days from the date of inspection. If more than one individual carried out the inspection, this time may be longer as they have to wait for each individual’s findings and include them in the end report. After you have received the report (which is usually received by email) you will have 10 working days to check the contents, making sure that it is factually accurate.
A comments template will be sent with the report which you are encouraged to use. This is the only opportunity you will have to comment on the information in the report before it is published online on the CQC website. A final copy of the report is sent to you approximately 15 working days after the draft copy is sent. Ensure that you regularly check your emails post-inspection so that you can check the inspection report as soon as possible.
The CQC has a profile page on their website for every health and social care provider that is registered with them. This profile will include a summary of their findings from their latest inspection, and their judgements on whether the provider meets the necessary standards outlined by them. Each profile will also include links to PDF documents detailing all of the inspections that have been carried out at that location.
Interpreting your rating
When looking at your profile, you will be able to see a tick or cross next to 5 different chapters, which will cover the CQC’s essential standards (including the fundamental standards). The tick or cross will be determined by your worst rating within that chapter.
A green tick shows that the service provider is meeting the set standards.
A grey cross shows that the service provider is not meeting the set standards, and improvements are required.
A red cross shows that enforcement action has been taken due to standards not being met.
When you click on a chapter you will be able to see which of the essential standards have or have not been met, a summary of why they have not been met, and the date at which that standard was last inspected by the CQC.
If you are not meeting the correct standards you will be faced with compliance actions. If this applies to you, a template will be sent in order for you to submit a report on how you intend to meet the regulations, and the individual actions you will be taking to achieve these goals. Your plans will be checked for robustness against the SMART approach: they must be specific, measurable, attainable, relevant and time-bound.
Make sure that your report is returned within the timeframe outlined by the CQC. This will be either 7, 14 or 28 days from the template being sent.
Once you are meeting the standards that were found to be lacking, and are able to evidence this, the CQC may follow up with an in person visit or a telephone call. They will confirm whether you are now meeting the necessary standards, will publish their report, and continue to carry out enforcement action if necessary.
CQC inspection is aimed to protect your patients or residents, which should also be your in your interest. It is not to catch you out. You can learn more about change management here.