CQC will use your previous practice rating to determine when to next inspect your service.
| Previous rating | Maximum time between inspections |
|---|---|
| Inadequate | 6 months |
| Requires improvement | 1 year |
| Good or outstanding | 5 years |
Being told you're going to be inspected
Before the inspection, an inspector will phone the practice to announce the inspection and a letter will be sent to confirm the date. You should be given two weeks’ notice. Practices should display the comment cards and posters that are supplied with the letter.
You will also be asked for some information, and have five working days to respond. It should be clear what information you need to send, where to send it, and who to contact if you have any questions.
- an action plan that addresses the findings of any patient surveys
- a summary of any complaints received in the last 12 months, any action taken and how learning was implemented
- a summary of any serious adverse events in the last 12 months, any action taken and how learning was implemented
- evidence that the quality of treatment and services has been monitored, including evidence of two completed clinical audit cycles in the last 12 months and any other audits, with evidence of outcomes or actions taken as a result
- recruitment and training policies and procedures, eg how staff are recruited and vetted before joining, arrangements for EEA and overseas-trained doctors, and what induction they receive
- number of staff by role (whole time equivalent)
- a copy of the current statement of purpose.
The list isn’t exhaustive, but these items and information are likely to be requested on the day of the inspection. Collate as much as possible beforehand and have it ready:
- significant events
- audits including infection control, cleanliness, and disability access
- risk assessments, with evidence that reasonable action has been taken – an active document
- health and safety documentation
- business continuity plan
- HR staff files, policies and procedures including a locum policy and induction programme
- service operational policies including safeguarding, complaints, chaperoning, medicine management and repeat prescribing
- equipment calibration reports
- PAT testing reports
- palliative care registers
- workforce training matrix and schedule.
Speak to your LMC if you would like an LMC rep to attend your inspection as an 'observer'.
The practice walkthrough
The registered manager and practice manager or deputy should walk through all areas of the practice to check the following (the list isn’t exhaustive).
General
- De-clutter and tidy all areas of the practice.
- Be aware that the inspector may ask about the contents of the doctor’s bag, the emergency drugs and contents, fridge temperatures and associated logs.
Health and safety
- Identify where controlled drugs are kept and carry out a risk assessment to identify any potential hazards, which may remain in a locked fridge.
- Keep an accident or incident book in a recognised area for staff to complete.
- Ensure fire equipment is in the right place and in date.
- Have a first-aid box in a recognised area and an appointed first-aid trained lead.
Patient information and areas
- Have an appropriate place for people to comment (positive and negative) about the practice’s care and service.
- Make it easy for people to complain – are you displaying notices?
- Have an identified isolation room and policies for its use.
- Have a confidential or private area for patients to use, including a breastfeeding area where possible.
- Display information about the patient participation group.
Security
- Ensure medical supplies cupboards are locked.
- Keep important keys in a secure place.
Stock
- Remove all (clinical and non-clinical) out-of-date stock, material and medical-related resources, eg the British National Formulary.
- Ensure the practice has good stock control systems.
Prepare your staff
Ensure staff members are aware of the CQC and what’s expected on any visit.
Consider creating a shared resource for all CQC compliance documents, including policies, procedures, templates, etc, so the entire practice can access them easily.
Plan now for absences of the practice manager or registered manager during the inspection.
In all meetings:
- include the CQC as an agenda item when appropriate, and take minutes
- have agendas and minutes - all staff should be able to add items to the agenda and read copies of the minutes
- other agenda items to consider for all meetings include managing risk and improving quality.
Minutes must be available to show the CQC inspector that the meeting took place.
Promote your practice
Think about how your practice can best present and promote its services and care. For example:
- ensure senior staff are working on the day of the inspection
- prepare a welcome pack for the inspectors, including the staff rota for the day and lead names on particular areas, eg infection control, cleanliness and safeguarding
- display the CQC registration in a public space in the practice and on your website
- ensure all premises and equipment are clean, secure, suitable and used properly
- ensure your practice leaflet is up to date and the same information is on your website.
Staff training
- managing risk and learning from mistakes
- health and safety
- CPR
- equality and diversity
- informed consent
- informed decision making
- whistleblowing
- chaperoning
- safeguarding for children and adults
CQC inspectors may want evidence that safeguarding adults and children is discussed in multidisciplinary meetings, and all policies are followed. In particular, they may be interested in information sharing so any matters can be resolved quickly and easily. They may also ask about the management of access to sensitive information, eg the register of patients at risk. - GP awareness of deprivation of liberty safeguards, the Mental Health Act and the Mental Capacity Act, and what this means for GPs and their patients.
Inspectors may ask to see proof of attendance certificates in connection with staff training.
To help you evidence skills and appraisals for practice nurses, download the RCGP’s general practice nurse competencies.
Patient involvement
Involve the PPG in discussions of care, experience, quality and safety.
- All people and population groups should receive the same outcomes, so practices should consider how they will demonstrate this when asked.
- Install a hearing loop and associated signage.
- Wherever possible, inspectors will observe staff and patients’ interaction, eg in the reception area.
Your practice manager, a member of the PPG or a colleague from another practice could sit in the reception area to observe for a period of time and report back on any changes required (eg confidentiality at the reception desk, ensuring posters and information are relevant and clear). - Consider creating patient surveys to assess how effective your services are for the CQC’s six defined population groups.
Inspectors may ask how your practice shares the patterns and trends of complaints, and for evidence of change to improve services. You may wish to consult with patients and the PPG at least annually. You should also be aware of the CQC’s human rights approach.
Introductions and presentation
First, the CQC inspector will meet with your registered manager. If the registered manager is not available, they can meet another senior member of staff, eg a partner.
They should briefly introduce and explain who the inspection team is, the scope and purpose of the inspection, how any concerns they identify will be escalated, and how their findings will be communicated.
Next, they will ask the practice to present its own view of its performance – particularly in relation to the five key questions and six population groups – and to include any examples of outstanding care and practice. This should take no longer than 30 minutes, but you can choose any format or medium. You may wish to include a patient view.
What inspectors might ask you
Quick tips
Inspectors may ask about appointment availability for patients to access:
- female or male GPs and nurses
- pre-bookable appointments in advance
- urgent appointments.
Ensure you’re aware of the systems in place, but also be honest about challenges in achieving good access.
Your practice will need to demonstrate how it works with other service and care providers. Inspectors may ask about:
- any interpreter service used, including access to sign language if required
- the handover to out-of-hours services, especially for patients near the end of life.
The practice may be inspected for cleanliness and infection control; these actions can help to meet minimum standards.
- Ask a practice nurse to lead on the CQC’s regulations for infection control and cleanliness and ensure they’ve adequate training to carry out the role effectively.
- Document – and save in a shared place – infection control audits, cleaning schedules (including deep clean), cleaning logs and training undertaken on a systematic basis.
- Notices and logs when areas were last cleaned, eg in toilets, clinical rooms and waiting rooms.
- Provide hand gel.
- Where practical, ensure carpets are not stained or discoloured.
- Show how the practice mitigates risks including sharp disposal and injury.
Consider how your practice can demonstrate clear leadership, supportive management and a fair culture.
- Conduct frequent staff meetings with a shared agenda and minutes.
- Ensure staff have read, understood and signed up to the statement of purpose.
- Ensure staff feel supported and valued, and have appropriate employment policies, procedures and systems.
- Inspectors may ask for evidence of formal recorded supervised support for the entire workforce.
- Inspectors may wish to talk to staff about whistleblowing and whether they feel safe to do so.
- The entire workforce should be able to identify and learn from mistakes.
Inspectors want to get to the heart of people’s experience of care, so they will focus on the quality and safety of services, based on the things that matter to patients.
- Use past case examples to help demonstrate compliance.
- Describe in detail the service offered and how staff ‘go the extra mile’ to achieve the best possible outcome for all patients.
- Inspectors will talk to patients (pre and post-consultation) about their experience; whether they felt listened to; consent; informed decision making; choice; access to appointments and information about a particular treatment or referral options; prescribed medication, including about the risks and benefits; and general safeguarding.
- Inspectors might sit in the waiting room to listen, talk to patients and observe the greeting of patients at reception.
Inspectors might want to see policies, procedures, guidelines and protocols, but what’s more important is that the practice workforce understands what they mean in operational terms.
Documents must reflect what the workforce does on a daily basis. It may help to have an intranet where the policies can be accessed easily by all.
Ensure the practice is ready to answer questions related to safe staffing and have supporting evidence. For example:
- a robust recruitment and selection policy that meets the equality agenda and minimises risk
- recruitment paperwork, eg advert and interview notes in personnel files
- inspectors may wish to discuss recruitment processes, especially GP locum appointments
- evidence of a staff induction programme with a section on the CQC and disclosure of criminal activity
- annual performance appraisals, documented and saved in an appropriate domain - it is good practice to include a section on managing risk in appraisals, including criminal activity disclosures
- evidence of DBS checks (or risk assessment if non-clinical). Undertake a risk assessment (to include all non-clinical staff without a DBS), take reasonable actions and use it as a working resource.
- HR files for all staff – including locums and partners – with an index of key information.
Managing risk and quality
If asked to demonstrate compliance, you can use some of these examples (the list isn’t exhaustive).
- the systems in place for risk management and clinical governance, and evidence of any change in practice as a result
- conducting clinical audits
- conducting regular significant event reviews and analysis
- conducting risk assessments and undertaking all reasonable actions incident reporting related to controlled drugs and other medicines, and evidence of learning or action taken
- reviewing and updating the process for staff to read policies, protocols or procedures
- local or national guidance having been taken into account
- reviewing information gathered about the safety and quality of GP services. From reviews, practices can identify any risks and actions to address them, and find ways to improve services
- circulating and acting on clinical guidance, medical alerts, safety alerts and other relevant local or national reports, so staff can change their working practices if necessary.
- any external accreditation process
- records of training and development for all staff
- information on any staff misconduct investigations
- discussing information collected at team meetings, so learning and development needs are identified. Staff should also feel able to raise concerns about risks to patients and staff in confidence at any time.
- the mechanism for patient feedback and comments
- evaluating changes to ensure improvements were achieved
- the procedure for handling complaints – it should be publicised and robust, and comply with local authority social services and NHS Complaints (England) Regulations 2009
- data about the quality of the practice in some form, in public areas of the reception or on the website – eg results of a practice survey or summary of patient feedback from a suggestion box.
- display health and safety information, including the practice’s responsibilities.