This month, the focus is on the most important key question that connects every single GP service that has ever been rated ‘requires improvement’ or ‘inadequate’. It is of course the Safe key question. Why is this the most important? Not only does it link to Regulation 12, which covers safe care and treatment, but it’s the key question with the most key lines of enquiry and the one with the most recorded breaches in GP practices.
So, what happens if you fail to meet the requirements of Regulation 12? You’ll be rated either ‘requires improvement’ or ‘inadequate’ and you may receive a breach notification. But there are ways to avoid this happening and one such way is to look at some of the common own goals scored by service providers (there are quite a few!) and then make certain you avoid the same mistakes.
The following examples are taken from inspections conducted by the CQC and are common across England. You’ll see the problem followed by the recommended solution.
| Training | Solution |
| Staff were not trained to the appropriate level for safeguarding children and vulnerable adults. | Use the Mandatory Training Troubleshooterand look at CQC GP mythbuster 25, to ensure all staff are trained to the appropriate level. |
| Staff were not suitably trained in emergency procedures.
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Ensure all staff receive training in anaphylaxis, basic life support, recognising sepsis and how to deal with emergencies. See CQC GP mythbuster 70. |
| Not all staff had received the appropriate level of infection prevention and control training.
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Non-clinical staff are to be trained at level one and clinical staff at level two. See CQC GP mythbuster 99. |
| Lack of evidence of training. | Create a training matrix or use Learning Manager, which is part of the Compliance Package, accessible on the HUB to record all staff training. |
| Recruitment & occupational health | Solution |
| DBS checks had not been undertaken for all staff. | Ensure DBS checks are undertaken and if it is decided that a DBS check is not required, then this should be fully supported by a robust risk assessment. See CQC GP mythbuster 2. |
| Recruitment checks had not been carried out appropriately. | Adhere to Regulation 19 and follow the organisation’s Recruitment policy. |
| Staff immunisation requirements were not adhered to, and records were not accurate. | All staff must have the necessary immunisations as detailed in the staff immunisation policy and CQC GP mythbuster 37. |
| Premises, health & safety | Solution |
| Actions had not been taken in response to the health and safety and fire safety risk assessments.
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Complete and resolve the actions required, noted down by the professional. It’s too easy for a CQC inspector to simply read a risk assessment that found issues and then spot that those issues have not been resolved. If you hand a CQC inspector a fire risk assessment that states you need to change a door to make it safe, that exact wording will be used in your CQC report if you haven’t installed it. |
| Emergency medicines | Solution |
| Not all recommended emergency medicines were held.
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Follow the guidance detailed in CQC GP mythbuster 9. Where a decision is made not to hold specific medicines, a risk assessment must be undertaken which justifies why specific medicines are not required. |
| Information sharing | Solution |
| Learning from significant events was not widely shared with practice staff.
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Minute all of your meetings and ensure that significant events are a standing agenda item. Before any CQC inspection, ensure staff are reminded of the significant events and the outcomes. |
| Actions had not always been taken for safety alerts received.
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Ensure there is a robust system in place to manage all safety alerts. You can use Safety Alerts Manager, part of the Compliance Package, accessible on the HUB.
Make sure that if the alert requires risks to be discussed with the patient, this is documented and, if necessary, apply the short-scripting protocol to ensure compliance. These should also come up in the Ardens searches. Discuss the alerts at staff meetings and maintain a record that shows how each alert has been disseminated to all relevant staff. Then audit this process and consider how it can be improved. |
| Medicines management | Solution |
| Blank prescriptions were not logged or tracked at branch sites. | Ensure the security of blank prescription forms is robust and you adhere to CQC GP mythbuster 23.
Staff must also follow the guidance detailed in the organisation’s Prescribing policy. Ask a staff member to lead on this so that the management of new prescription paperwork is continually maintained. |
| There was no embedded process in place to review the prescribing practice of non-medical prescribers. | Follow the organisation’s Clinical supervision policy and ensure that all non-medical prescribers have a supervisor who has recorded that their competency has been checked. |
| There were some gaps in the process for monitoring patients’ health in relation to the use of medicines including high-risk medicines. | Run the Ardens searches routinely and create a system to constantly address the gaps where patients are coming up as requiring monitoring. All services have numbers of patients who require monitoring across the Ardens searches.
A lot of services have failed to demonstrate that they know or understand how to show that they are working to ensure patient safety in this area. One of the best approaches to implement is a short-scripting protocol which takes effect within two months after several attempts to contact patients. Services need to demonstrate that this protocol is active and effective so that the CQC can see its involvement with all patients who are flagged as requiring monitoring. |
| Medical records management | Solution |
| Individual care records did not contain all the patient information – for example, blood test results were not routinely added to patient notes. Medicine reviews did not always contain documentation of the discussions that had taken place with the patient. | Ensure there is a robust correspondence management protocol in place that is aligned to CQC GP mythbuster 46.
You could get one staff member to champion this undertaking by keeping a list/audit of all blood test results which they could maintain/monitor on a scheduled basis. For medication reviews it is best practice to ensure that all of your clinicians use a set template to drive consistency and ensure all information is recorded and considered. Ask a clinician to audit medication reviews on a scheduled basis to ensure that sufficient detail is being recorded each time. |
| There was a backlog of summarising of new patient notes.
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Undertake an audit of your patient list/system to check how many new patients need summarising. Then direct a staff member to work through the backlog (if there is one) and record their progress. Ensure there is evidence of how you are managing summarising. |
Hopefully you’ll agree that these solutions will help you to avoid scoring an own goal when it comes to a CQC inspection! Preparation is essential and evidence is key, if you are to satisfy the CQC. Take a look at the Compliance Package on the HUB which is packed full of extremely useful features including CQC Manager.
In next month’s blog, we’ll look at the Effective key question.
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