Inspection Basics

Overview of the CQC Inspection Model

 A quick overview of how "Key Domains" and "KLOEs" work

The New CQC Inspection Model 2014

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Get to know KLOE

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.

 

 

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The 5 Key Questions or Domains

The CQC's inspection model focuses on 5 key questions that a service provider is going to be judged on.

"SCREW - KLOE"
A rude acronym that makes it easier to remember the latest Guidelines.
Rejigging the acronym provided by the CQC makes it easy to remember and offend. These are as outlined below:

 SCREW Explained

KLOE explained

 

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Types of Inspections

The CQC have outlined three types of inspections that wil be carried out. These are:

1. Comprehensive Inspections (Planned Inspections)

  • How frequently you are inspected, the size of the inspection team and whether or not you get notice of inspection depends on the nature of the Service provision and organisation.
  • The CQC call their new Inspection model under KLOEs a Comprehensive Inspection.

2. Focused Inspections (formerly known as follow-up inspections)

  • To look at something that is of concern; usually after an improvement notice has been issued after a previous CQC visit.
  • Focused inspections are carried out to check that compliance actions have been implemented
  • These are smaller in scale than comprehensive inspections, although they follow a similar process.
  • Generally a notice of the inspection will not be given (GP practices however still get notice of inspection)

3. Responsive Inspection

  • These are carried out when concerns are raised over a provider’s compliance with the standards. (Information may come sources such as a whistle blower, the CCG, the GMC or a member of the public.)

How often will they inspect?

The CQC aim to inspect a primary medical service provider approximately once every 2 years, but some practices may be inspected more often.

Will I get advance notice of an Inspection?

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.

 

 

What is Intelligent Monitoring

Intelligent monitoring overview

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What is Intelligent Monitoring

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.”

Editors Comments:

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.

 

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How do CQC gather their Intelligent Monitoring information

How do CQC gather the Information

Intelligent monitoring

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:
• Local Healthwatch.
• Patient participation groups, where they exist.
• Local voluntary and community groups.
• Patient and carer groups.
• Community outreach focus groups.

Some local organisations have a responsibility to gather and use people’s experiences of care and we will request information they hold, for example:
• Overview and scrutiny committees.
• Quality surveillance groups.
• Local NHS complaints advocacy service.

CQC will publish further detail about the information we will request, but it is likely to include:
• Results from patient surveys and associated action plans.
• A copy of the provider’s statement of purpose.
• 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 for the last 12 months, any action taken and how learning was implemented.
• Significant event analysis.
• Locum/agency use over the last 12 months (out-of-hours services only).
• Evidence of monitoring the quality of services provided.
• Evidence of supplying urgent/emergency medicines.

intelligent monitoring sources

 

 

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What is a Quality Risk Profile (QRP)?

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.

How is the Quality Risk Profile Compiled?

The QRP is developed based on the information CQC have on you.

The information is gathered from various sources including:

  • Quality and Outcomes Framework (QOF)
  • Hospital Episode Statistics (HES)
  • Quality Management Analysis System (QMAS)
  • GP Patient Survey
  • Information from Committee of General Practice Education Directors (COGPED)
  • Concerns, complaints and safeguarding alerts
  • Contract monitoring reports
  • Comments from the NHS Choices website
  • Provider compliance assessment – Your registration document
  • The practice’s own website

In the future they will also rely on:

  • Your last inspection report
  • The notifications sent by you
  • Your PIR report before an  inspection

 

 

How can I check my QRP?

If you have registered, you can access your Qulaity Risk Profile by Clicking here.

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