A quick overview of how "Key Domains" and "KLOEs" work
The acronym KLOE, stands for Key Lines of Enquiry.
The starting point for the inspection are the five key questions – are services safe, effective, caring, responsive and well-led?
A 'KLOE' is basically a set of 'key' questions the CQC will look at under each of five headings to reach a conclusion as to how your service should be rated.
The CQC have outlined three types of inspections that wil be carried out. These are:
1. Comprehensive Inspections (Planned Inspections)
2. Focused Inspections (formerly known as follow-up inspections)
3. Responsive Inspection
The CQC aim to inspect a primary medical service provider approximately once every 2 years, but some practices may be inspected more often.
In 2012 a concession had been agreed and only GP practices were given a 48 hours’ notice.
Under major changes to the way visits are carried out, from April 2014 this 48 hour period increased to a two weeks’ notice before a CQC inspection.
A CQC statement has said: ‘CCGs are being given at least four weeks advance notice that their area has been selected and GP practices in those areas will have at least two weeks’ notice of an inspection as opposed to the previous 48 hours, CQC reserve the right however to inspect unannounced at any time where a practice is identified as a risk.
As reported by Pulse, the Chief inspector of primary care Professor Steve Field has claimed that the change heralds a ‘new approach’ in the way the CQC works with GP practices, aiming to support them to raise standards.
Whilst a 2 week notice period is the CQC's 'official' position, find out more as to what happens in reality.
As part of the New model of regulation and inspection, the CQC recently published their Intelligent Monitoring dataset for GP practices across the country.
(Click here to see the CQC map)
The Intelligent Monitoring (IM) report pulls together information, available in the public domain e.g. QOF reports, Patient survey etc. to give the inspectors a clearer understanding of strengths/weakness of each provider, therefore allowing for targeted inspections visits.
Whilst the CQC are claiming that this part of their new inspection methodology, as far back as early 2009 they announced they would be compiling a risk profile on each service provider. “Practices identified as at high risk could expect to face a toughened-up inspection regime while low-risk practices might enjoy a lighter-touch approach.”
Whilst the CQC have set themselves targets to inspect all GP practices over the next two years it is common knowledge that they are somewhat behind in meeting these targets due to a shortage of inspectors. Targeted inspections is an efficient use of the CQC resources to prioritise when, where and who to inspect first.
Do remember that the intelligent monitoring data is nothing new. CQC has used Quality and Risk Profile (QRP) for each provider type over the last few years as an internal tool to monitor compliance; and the publication of the IM report is CQC's effort at transparency. (IM reports have been published for all healthcare sectors monitored by the CQC)
The final judgement of a practice is based on the inspection report and not the pre-inspection banding/risk rating etc. When CQC identifies a ‘risk’ or ‘elevated risk’, it does not necessarily mean that people using the practice are at risk, but where certain patients may be at risk.
The CQC aim to update the IM report regularly, based on the most current indicators available to them. So the easiest way to change or improve your banding is to ensure that your practice is achieving the national targets.
This graphic shows where the CQC will get information about you. Most of it is obvious: Complaints to CQC; whistle-blowers; Your registration form; IG Toolkit; QOF reports; Patient surveys etc.
A basic rule of thumb is that if you have published information about yourself to the NHS, they will use that in the pre-preparation.
In addition, if anyone else has posted information about you, they will also use that under the header “People who use services”
The data in the IM report includes information from:
Whilst most of this is expected, it is worrying that in addition to NHS Choices the CQC believe that information from private websites will also be considered legitimate “intelligence” for an inspection.
CQC promoting a private website in its guidelines is quite extraordinary we think!
This data gathering angle has the potential for a worrying trend.
CQC will also ask local organisations to provide information, including:
Some local organisations have a responsibility to gather and use people’s experiences of care and we will request information they hold, for example:
CQC will publish further detail about the information we will request, but it is likely to include:
The CQC have developed a Quality Risk Profile about your organisation to support how they monitor your compliance.
The QRP helps the compliance inspectors to assess where risks lie and may prompt front line regulatory activity e.g. when carrying out a planned review of compliance, to identify and prioritise potential risks of non-compliance; which may trigger regulatory action that can include a responsive review of compliance.
The QRP is developed based on the information CQC have on you.
The information is gathered from various sources including:
In the future they will also rely on:
If you have registered, you can access your Qulaity Risk Profile by Clicking here.