Useful Guides

CQC – New Fundamental Standards: Part 5, Inspections

This is what your new inspections will look like

This article will expand on the approaches to inspections which the CQC will use.

In their draft Provider Handbook, published in April 2014 for consultation, the CQC sets out its proposals for how inspections will work after 1^st October 2014.

Some key overall points are:

Community services inspections will usually be pre-announced 48 hours before they will take place. This is not done in order to negotiate a suitable day, but to inform the service that the inspection is to take place on the appointed day, and to make sure that the manager, or a senior person in charge, is there on the day. “A senior person in charge” implies a working deputy to the manager if the manager is unavoidably absent. This is not the Provider if they are not in day-to-day management control, and therefore not able to provide detailed operational information. The inspector is interested in what is actually happening in the service, not what the Provider hopes or assumes is happening.

For residential services, site visits will normally be unannounced.

According to the handbook, the inspection team will consist of either one person, or a small team.

The expanded team may involve Experts by Experience, who will be people with personal experience of services either directly themselves, or by being a carer for someone else who has received care. They will be responsible for contacting service users for their opinions. The Expert will feed back to the Inspector, and may accompany them on their site visit.

Inspection frequencies will depend on the rating of the service:

Inadequate - within 6 months of the last inspection
Requires Improvement - within 12 months of the last inspection
Good - within 18 months of the last inspection
Outstanding - within 24 months of the last inspection

In addition to these inspections there will be inspections that:

Respond to risk
Are carried out to follow up on any action the CQC has told the Provider to take

The CQC will also each year inspect 10 per cent of randomly selected ‘good’ and ‘outstanding’ rated services that are not due an inspection in accordance with the timescales above.

Planning Inspections

The CQC inspection planning will take into account:

Intelligent monitoring, as explained in our previous article
Registration information
Previous inspection reports and follow-ups
Comments and feedback from people who use the service, and the public
Healthwatch feedback
Local voluntary and community groups, including equality groups
Feedback from questionnaires sent by the CQC
Feedback from telephone interviews
Information from other agencies. Fire and environmental agencies are mentioned for residential services, but none are specified for community services.
The Provider Information Return (see a later article)
Statutory notifications
Applications for variation of registration
Information from staff, in the form of feedback from questionnaires

The site visit

The visit will begin with a meeting with the senior person on duty, and the inspector expects to see the manager, registered person, nominated individual, or senior person in charge.

The inspector will inform you which Key Lines of Enquiry they will be inspecting, and:

Whether they are following up on any previous issues
The proposed length of the inspection
The roles of the inspection team members
Who they plan to speak with
Documents they want to review
How they will feedback about what was found during the inspection

During the visit the inspector and/or the Expert by Experience will gather views about the service from people who use it, individually or in groups depending on the service type, speaking to them either in person, by telephone or by visiting them at home, and speaking to families and visitors, again depending on the service type. Where there are communication barriers they will use interpreters, other specialists and care staff expertise. The inspector will also speak to friends and relatives of people who use the service, either on the telephone or in the person’s home, before, during or after the day they visit the service office.

Information will also be gathered from staff, by which they mean the Registered Manager, senior person on duty, or care and support staff, cleaning staff, catering staff, maintenance staff, (depending on the service type) or all of these.

Other information will be gathered by:

Observing care (but not intimate personal care)
Using the SOFI 2 (Short Observational Framework for Inspection) tool when there are people using the service who are unable to tell them about the care they receive (in residential services)
Tracking individual care pathways (care plans)
Talking to volunteers, community professionals and other people involved in the service
Looking at the environment, including individual and communal rooms (in residential services)
Reviewing records

In some situations where they have concerns they may seize some forms of evidence, use photographs and take copies of documents. They may also need to gather evidence under the provisions of the Police and Criminal Evidence Act 1984 (PACE). If they do this, they will explain to the senior person on duty what they are doing and why.

Throughout the inspection the inspector will continuously evaluate the evidence they have seen, and make adjustments to their assumed schedule to take account of findings, obviously in particular any concerns they may have.

If the inspector finds any concerns around safeguarding, they will invoke the CQC safeguarding protocol and bring the matter to the attention of the manager or person in charge. If the person subject to the abuse is deemed to be at risk, the Inspector will take immediate appropriate action.

Closing the visit

At the end of the inspection visit to the service, the inspector will hold a feedback meeting with the person in charge on the day of the inspection. At this point in the inspection the inspector will only be able to give high level feedback which will not include what the rating for the service might be.

At this meeting the inspector will:

Explain what has been found during the visit
Highlight any issues that have emerged
Explain that this is preliminary feedback and that they cannot make a judgement until they have considered all the evidence together. For example, there may be evidence from Experts by Experience to analyse, or feedback from people they could not speak with on the day
Say when the report can be expected, how any factual inaccuracies can be challenged and what the publishing arrangements are
Answer any questions from the person in charge and receive their feedback on the inspection process so far
Say what the next steps will be

Background

In Part 1 of the series we have seen how the Care Quality Commission has proposed to implement from October 2014 a new regime of registration and inspection in response to failures of the current regime to spot and deal with poor quality care before too many people were harmed.

We saw that the CQC proposes a new, clarified and re-focussed registration and inspection regime, demonstrated by the following schematic.

The schematic demonstrates that the CQC regard their overall registration process as having five steps, these being: