Is your practice safe? Caring? Responsive? Nicki Rowland drills down into those all-essential CQC questions

I've already discussed staff training and why it is vital for practice growth. Additionally, training and staff development is also a fundamental part of what the Care Quality Commission is looking for within their ‘effective’ and ‘well-led’ key lines of enquiry (KLOE).

A catalyst for change

Published in February 2013, the Francis Report highlighted extensive failings within the Mid Staffordshire NHS Foundation Trust. The government's official response was to announce numerous new patient safety initiatives that would endeavour to position the NHS amongst the safest healthcare systems in the world. Not only that but private healthcare organisations that often fell beneath the radar were to be monitored for safety too by introducing a new CQC inspection regime in April 2015. Inspections are now consistent and focused by using ‘key lines of enquiry’ or KLOEs. KLOEs are intended to help inspectors judge the quality of care against five principal questions which are:

Are they safe?
Are they effective?
Are they caring?
Are they responsive to people's needs?
Are they well led?

Are you safe?

‘By safe, we mean that people are protected from abuse* and avoidable harm. *Abuse can be physical, sexual, mental or psychological, financial, neglect, institutional or discriminatory abuse.’ In their How CQC Regulates Primary Care Dental Services: Provider Handbook, March 2015, it clearly defines ‘safe’ and there can be no mistaking the CQC's definition of abuse either. But what does that mean to us exactly in practice? Well, the CQC are searching for evidence that we have ‘systems, processes and practices in place to ensure all care and treatment is carried out safely’. For example, they want to see that dental teams have a clear understanding and reporting of RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013) and COSHH (Control of Substances Hazardous to Health). Team members are required to record any safety incident, to learn from it and to put quality assurance measures in place to prevent a future event. Providers must also respond to safety alerts issued by the Medicines and Healthcare products Regulatory Authority (MHRA) and the Central Alerting System (CAS). Dental practices are required to deliver person-centred care where valid consent is gained and patients, particularly children and vulnerable adults, are safeguarded from abuse and improper treatment. If something does go wrong with treatment, we now have a Duty of Candour (Regulation 20) to apologise to the service user and openly and honestly guide them through a process that rectifies the issue with an agreeable outcome. Practices are required to be appropriately staffed and those employed are required to be ‘fit and proper persons’ for their roles. Good governance systems should be in place to assure the safety of both patients and staff from facilities and equipment that should be clean, secure, properly maintained and kept in accordance with related guidance and legislation e.g. Ionising Radiation Regulations 1999 and Ionising Radiation (Medical Exposure) Regulations 2000 (IRMER). There should be sufficient instruments to take account of decontamination processes (HTM 01-05) and sharps and prescription drugs should be stored, handled and disposed of according to appropriate guidance and legislation. This narrative is not a definitive summary of the ‘safe’ KLOE but merely gives a taste for what the CQC expect.

Are you caring?

During a CQC inspection, patients will be interviewed informally to gauge their views on their practice and the level of care within it. Inspectors want to hear that service users are respected and treated with dignity at all times and that they are listened to and fully involved with decision-making that relates to their treatment and care. Individuals' requirements and needs should always be considered in line with their diversity, values and human rights. In England, we are now required to have an emotional care policy that reflects the support and emotional care offered to patients in our practices. Staff should give patients the time they need to interact and facilities should be available should a patient wish to converse in a private and confidential environment. Treatment options and costs should be fully explained and patients should be allowed the opportunity to ask questions and the time to think about the best choice for them. Team members should be aware of how individuals respond to pain, discomfort and distress and give them timely and fitting support.

Patients' views about the service and care at their practice should be actively sought by way of a patient survey. Any negative feedback should be dealt with appropriately and ideas for improvement should be implemented, where appropriate, in line with good quality assurance processes. Acting upon patient feedback also shows that you are ‘responsive’.

Are you responsive?

By responsive, the CQC means that ‘services are organised so that they meet people's needs’. Therefore, premises and facilities should be appropriately equipped, maintained and cleaned to suit the delivery of planned services. Providers should make ‘reasonable adjustments’ to ensure that people's needs and preferences are met with regards to treatment options, the dentist they see and the physical environment. A patient's needs relating to age, gender, race, religion and physical condition should also be considered. Appointment times should be scheduled to best suit individuals' requirements within the realms of what is possible day to day in practice. Patients should be informed of practice opening times and know how to access emergency care should they need it, including out of normal hours. Emergency care should always be delivered in a timely manner that is conducive with NHS contractual requirements and NICE guidelines. Waiting times, delays in treatment and cancellations should be kept to a minimum.

Patients should be able to report to a CQC inspector that they know how to complain if necessary. A complaints procedure should be displayed in the practice where all patients can see it and should be understandable and easy to follow. All team members must know the complaints procedure, how to escalate a complaint and understand their obligation to implement a ‘duty of candour’ (Regulation 20). The introduction of Regulation 20 is a direct response to the Francis Inquiry report. Robert Francis QC uses the following terms to describe the regulation:

Openness – enabling concerns and complaints to be raised freely without fear and questions asked to be answered.

Transparency – allowing information about the truth about performance and outcomes to be shared with staff, patients, the public and regulators.

Candour – any patient harmed by the provision of a healthcare service is informed of the fact and an appropriate remedy offered, regardless of whether a complaint has been made or a question asked about it.

A final thought

Transparency, openness and honesty nurture patient trust and loyalty. Not only that but, if you can demonstrate you are safe and caring. too, patients will want to come to see you.

Many people see the CQC regime as a negative thing. However, Fundamental Standards give us a perfect framework to meet best practice in all areas of work. Your CQC report is your most powerful marketing tool so why not go the extra mile and make it outstanding. Patients will come flocking!

Be prepared – top 10 tips

Make sure you have documentation that all cleaning has been checked by you or a dedicated member of staff on a weekly or monthly basis. You need to have the documentation to prove you have checked the cleaning as well as the documentation that the cleaner signs to say the cleaning is complete
Be aware, the CQC inspectors are very hot on cross checking complaints with significant events and training sessions to ensure any learning that came out of complaints or significant events was carried through
CQC inspectors may have different phrases from the practice regarding policy and protocols. For example, what you may refer to as an emergency procedure file, they call a disaster recovery policy and so on. Save confusion and try to learn their phraseology.
CQC inspectors are also very keen on the whistleblowing policy. Ensure you understand the concept of whistleblowing and that you know what to do if there was a problem.
They may ask about plans for the practice – visions and values – and even what you consider the practice to good at.
Other topics may include leadership, infection control audits, the practice accident policy, child protection and vulnerable adults and whether the practice has have one to ones. They will ask for staff minutes to prove you have looked into your significant events and complaints.
They will ask for a selection of staff files to ensure they are all consistent
They will ask about audits – clinical and non clinical – and request proof
They will expect all emergency medicines to be ordered and in a cabinet or bag
Best advice would be to make sure that your staff are knowledgeable about all areas of CQC. The inspectors will cross-examine all staff. If the practice principal or practice manager says one thing, they will then ask another member of staff the same question in a different way, to prove all correct.

Author: MA Healthcare