On 1st April, the CQC moved from a requirement to demonstrate compliance with their essential standards of quality and safety, or the ‘Outcomes’ as they called them, to a requirement to demonstrate compliance with their new fundamental standards regulations.
The fundamental standards are standards below which the level of care must not fall. Some new regulations were also introduced, such as a specific requirement to have a demonstrable governance system and specific requirements for what happens when things go wrong, as they inevitably do from time to time.
[blockquote cite=”Pat Langley” type=”center”]The CQC’s whole focus is on outcomes experienced by people who use services… patients to you and me![/blockquote]
Many of the criteria do remain largely the same though so it is important not to ‘throw the baby out with the bath water’. Many practices have been very concerned that all the work they did for the essential standards regulations is now redundant. This could not be further from the truth. The important thing is that everything is kept up to date and ‘live’ and that the whole team lives and breathes the practice policies and protocols.
Since the change, I have noticed that some practices also think that the CQC no longer focuses on outcomes for patients. This again could not be further from the truth.
The CQC’s whole focus is on outcomes experienced by people who use services (patients to you and me!). The reason for this confusion I think is because there is a difference between ‘Outcome’, meaning the regulation (as described in the CQC’s essential standards of quality and safety), and ‘outcome,’ meaning what actually happens as a result of implementing all your practice policies, protocols, procedures and processes, or to put it another way, what your patients actually experience when they visit your practice.
Types of CQC inspection
Two types of CQC inspection will take place in 2015/16 – ‘comprehensive’ and ‘focused’.
Comprehensive inspections seek to establish whether the practice provides care that is:
- Safe – meaning patients are protected from abuse and avoidable harm
- Effective – meaning your care and treatment achieves good outcomes, promotes a good quality of life and is based on the best available evidence
- Responsive – meaning that your services are organised to meet patients’ needs
- Well-led – meaning that the leadership, management and governance of the practice assures the delivery of high quality, person-centred care, supports innovation and learning, and promotes an open and fair culture
- Caring – meaning your patients are involved in their care and treatment and treated with compassion, kindness, dignity and respect.
10% of dental practices will have comprehensive inspections in 2015/16. These will be selected either randomly or on a risk-based basis and will usually be announced two weeks ahead of the inspection.
Practices classed as being a greater risk include:
- Practices that have been registered for more than 18 months and have not been inspected
- Those with a previous concern or risk identified or from information gathered from other sources
- Those with a concern or complaint received by the CQC, e.g. from a whistleblower or a patient complaint.
Comprehensive inspections are thorough and take one day. They are undertaken by a CQC inspector with support from a Specialist Advisor (often a dentist) who usually attends the inspection or sometimes provides remote advice. The inspectors speak to dental nurses, dentists, practice managers and receptionists and review policies and protocols. They expect these to be tailored to the individual practice and not just generic.
Focused inspections concentrate only on areas indicated by the particular information that triggered the inspection and will not seek answers to the five questions (safe, effective, caring, responsive and well-led).
Focused inspections will be in addition to comprehensive inspections and in response to concerns. However, if a focused inspection identifies significant concerns, it may trigger a comprehensive inspection.
What to expect at the CQC inspection of your dental practice
Before the inspection starts, practices will be asked to share any concerns they have identified themselves in their ability to meet the requirements of the regulations (including the new fundamental standards) and what they are doing about it. Inspectors will also ask the practice to share examples of where they provide what they call ‘notable practice’ that goes beyond the regulations.
This is a significant change in the inspection format because it means that practices need to know what the standards require in some detail in order to be able to say whether there are areas in which they are deficient or areas where the care they provide exceeds that required and is therefore ‘notable’.
What happens if a dental practice is judged to be non-compliant?
The new in-depth inspection results in a judgement on whether the practice provides care that is safe, effective, caring, responsive and well-led.
If the inspectors make a judgement that a practice is failing to provide sufficient evidence in one or more of these areas then the report that is published on the CQC website details areas that either need improvement or are deemed to be inadequate.
Practices are then issued with a Requirement Notice or a Warning Notice depending on the severity of the issues and the risk they pose.
Below is an example of what the CQC has published on their website for a practice that had out of date oxygen and emergency drugs, with some drugs missing altogether and no defibrillator.
‘We found that this practice was not providing safe care in accordance with the relevant regulations. We have told the provider to take action (see full details of this action in the Requirement Notices at the end of this report).
The provider did not ensure that sufficient medication was available in the case of an emergency. There was no process in place to ensure equipment and medical devices available were kept in full working order and some medical equipment was not available (i.e. an automated external defibrillator).
This was in breach of Regulation 12 (2) (f) of the Health and Social Care Act 2008 (Regulated Activities) Regulation 2014.’
Since the norm for almost anyone in this day and age when looking for a new service (restaurant, hotel, healthcare, etc) is to check out reviews, one can only imagine that a practice with comments such as these would be unlikely to be a new patient’s first choice.
This underlines the importance of ensuring you have done all you can to become and remain compliant at all times. As we say at Apolline, ‘Compliance is for life, not just for your inspection!’
[blockquote cite=”Pat Langley” type=”center”]The new in-depth inspection results in a judgement on whether the practice provides care that is safe, effective, caring, responsive and well-led.[/blockquote]
What do you need to do to demonstrate compliance with the new CQC standards?
Practices should ensure that they have a demonstrable governance system that enables them to monitor the quality of care delivered. This means that practices must:
- Undertake compliance audits and risk assessments and be able to demonstrate that these have been acted upon, e.g. infection control audits every six months
- Understand areas of non-compliance and have an action plan for becoming compliant
- Get feedback from patients and staff and be able to demonstrate this has been acted upon
- Record and analyse complaints and be able to demonstrate that learnings from complaints have improved service provision
- Keep comprehensive and accurate patient records that clearly demonstrate that patients have been fully involved in the treatment planning process and that valid consent has been obtained before treatment starts, and understand how the Mental Capacity Act applies in dental practice
- Undertake regular patient record audits and be able to demonstrate improvements made to record keeping as a result
- Record all significant events and be able to demonstrate that learnings from these have improved safety and service
- Train and involve the whole team in compliance because inspectors will talk to all team members.
And remember – help is available from a number of sources, so get help if you need it.
Before long, you’ll fully understand how the CQC changed the way it regulates and inspects dental practices.
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About the author
Pat Langley is Chief Executive of Apolline.
Apolline provides a comprehensive range of in-practice and remote support services to dental practices in all matters relating to regulatory compliance.
For further information, please call 0800 193 1033 or email the Apolline team at enquiry@apolline.uk.com
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