Mention an imminent inspection visit from the regulator the Care Quality Commission (CQC) to any general practice team and you can just imagine the nervous twitches, raised heartbeats and agitated moods that are likely to ensue.

No matter how good any primary care team may be, and regardless of their previous rating, be it good or outstanding, it’s natural that there will almost certainly be a feeling that the pressure is on, and the team will soon be thrown into a flurry of activity.

For the past year or so, boots on the ground from the CQC have been limited and to a certain extent the pressure has been off, largely due to the fact that in March 2020, the CQC suspended its routine inspections in response to the COVID-19 pandemic. This approach was welcomed by PMs across the land; however, for some new providers gearing up for an inspection in February 2020, they were perhaps somewhat disheartened to find their inspection had been cancelled.

Some teams had been psyching themselves up for an inspection and some had already invited their local CQC inspector to meet them at their practice. The building of a new relationship had already begun and then they were told that their inspection had been cancelled until further notice. Little did we know then that the cancellation was going to last for over a year!

But not all providers (new or old) adopt such a proactive approach when it comes to the CQC. Maybe some see the CQC as the ‘enemy’, lurking on the horizon, ready to launch an attack imminently. Others may feel confident (and proudly so) that they are going to blow the CQC out of the water when it comes to inspection day – hoorah!

The proactive approach is quite possibly the best approach and this is supported by practice manager leaders who want to encourage practices to be more proactive in reaching out to the CQC to develop healthy and constructive relationships with them. Anyone else thinking “keep your friends close and your enemies closer”?

What did work well, it appears, was the transitional monitoring approach (TMA) or sometimes it was referred to as the transitional regulatory approach (TRA) – a hands-off approach, allowing practices to focus on maintaining essential services during an extraordinary time for the country.

Pleasingly, the CQC are keen to maintain an approach that causes minimal disruption for service providers and in June they piloted a new approach in the East of England which saw the CQC carry out a virtual monthly check of service providers. In July, this approach was rolled out across England, although to date, it hasn’t yet been given a new name. So, let’s call it the ‘new approach’.

This new approach means that practices are now subject to virtual monthly checks, and the CQC is expected to look at the information it has on individual practices, including previous inspection reports and ratings, QOF, prescribing data, referrals, patient survey results and patient complaints. Basically, they are using CQC Insight to gather and analyse information about practices.

In reality, this means that many practices will simply be receiving a monthly email from the CQC saying that the regulator has looked at their data and found no reason for a full inspection at this time. Hang on, this sounds way too simple! Surely there’s more to it? Well, the CQC will call practices if they have concerns or want to discuss their findings in more detail. The cynic in me says that nearly every practice will get a call… sounds a bit like the ARR to me! If, however, the CQC have concerns then they may choose to carry out an on-site inspection.

Is this the time to brace yourself for an advance of the enemy? Stand down, because if you are targeted, you can use the CQC – A guide to success to help you effectively prepare for an inspection.

Jo Wadey, Practice Business Manager in West Sussex and a director at the Institute of General Practice Management (IGPM), says:

“The change in the CQC’s approach (i.e., monthly monitoring) isn’t really affecting us because most of us are not being asked to submit any information. From that point of view, it’s great for practice managers.”

Doesn’t sound like Jo was called to discuss anything with the local inspector this time. Nicely done, Jo!

This relatively “light touch” approach from the CQC has been welcomed even by those who aren’t exactly the regulator’s biggest fans.

Alasdair, a practice manager from Ipswich, says:

“The temporary arrangements that we’ve had over the last year have been helpful. They’ve got a bit more light-touch. I think it’s probably necessary that the CQC is changing from its previous arrangement, and it’s possibly a little bit better in the sense that it will be data driven.

“They don’t have the resources for a heavy-handed regime and they just couldn’t sustain it or the quality assurance so they’ve had to scale it down because I think they’ve overreached themselves. I think there were already signs that they were scaling it down before the pandemic anyway.

“From what I’ve seen of what people are being asked to produce, it varies from region to region, but some practices are still being asked to provide quite a substantial amount of stuff in my opinion. In those cases, if you get a ten-day warning to provide that stuff, it’s going to spoil your day.”

Unfortunately, one of the many gripes about the CQC is that, depending on where you’re located and who your inspector is, one thing is almost certainly guaranteed: the inspection process will differ, as will the requests for information and/or what is expected.

So, a data-driven approach, backed up by discussions, could be one way to resolve this ‘subjective’ boots-on-the-ground approach that many of us have experienced. So now we’ve got change on the horizon too. Take a look at an earlier blog by Phil, which focuses on these changes.

So, is it time to nurture a different relationship between practices and the CQC?

The IGPM’s Jo believes so and has met with the regulator’s Deputy Chief Inspector of Primary Medical Services, Vicki Wells, to discuss how practices can forge better relationships with their local CQC inspectors.

You can find out more by joining one of the summer webinars planned for Tuesday 24^th August, full details available here.

This ‘new approach’ is possibly showing us that the CQC is now striving to adopt an objective approach, using quantitative data. Seems logical to me, wouldn’t you agree?

A practice manager from London, who wishes to remain anonymous, says she’s had past issues with the CQC, particularly about their lack of consistency during previous inspections.

“When the CQC first came out, at that time you got two weeks to get your information together. We did that and were expecting a delegation of five people – an inspector, the GP, a nurse, a practice manager and a patient expert.

“At 4pm the day before the visit, we got a call to say they weren’t coming and they had to cancel. I’d put plans in place to enable them to talk to members of staff and patient groups.

“The next day, we had the patient representative turn up. Nobody had told them that the visit had been cancelled. It was rescheduled and then we had a delegation of three and no one had read any of the material that we’d sent over. They apologised and said they hadn’t had enough time.

“An organisation like that doesn’t seem to hold itself accountable to the same standards that it expects of general practice. I don’t have a lot of faith in the organisation generally.”

One thing is clear, from London to Luton, Leeds to Liverpool, Southend to Sunderland, Norwich to Northampton, there has been no uniform approach from the CQC. Is that now going to change with the ‘new approach’? Only time and your experiences will tell us! So please continue to tell us how the ‘new approach’ has been for you.

There’s a range of resources available to help you prepare for a CQC inspection including: A guide to the CQC annual regulatory review process, [PLUS], Preparing your team for a CQC inspection [PLUS], and a Presentation to CQC (PowerPoint template).[PLUS]

There’s also training available on the HUB for Practice Index Learning subscribers including: CQC for all staff and a CQC Masterclass: The Perfect Practice.