Are you feeling a bit anxious about the new whole patient population audit? Let me tell you what practices can do to mitigate and manage the CQC’s new detailed inspection approach.

Since 2022, the CQC have been auditing whole patient populations using Ardens search tools which can find any and all patients who are potentially ‘at risk of harm’. The CQC always complete ten random searches out of a selection of 32 searches. From the ten random searches, five patient records are specifically reviewed by a GP specialist advisor, and these are used to indicate what ‘risk’ patients may be facing. This means that the CQC will typical review approximately 50 random patient records in total. These random records will be used to make your ratings and decide whether any enforcement is necessary.

For example, a search of patients on Methotrexate (DMARD) could find that 100 patients are receiving this prescription and 50 of those patients have not had ‘sufficient monitoring’. Five specific patients would then be reviewed out of that 50 as a fair sample. If all five are confirmed as not having had blood tests completed within the last three months, then the CQC would categorise a service as ‘high risk’.

All services have patients who don’t attend routine appointments for blood tests and other monitoring processes. So, the CQC will always find some patients who require monitoring. However, if you don’t have systems, processes and protocols for managing these patients then you may be at risk of CQC enforcement and negative ratings. We suggest that all practices do the following:

Run the Ardens searches 

It may seem obvious, but some GP practices are still being caught out by this new inspection approach. If you don’t run the searches, you will have no idea of how many patients the CQC will find as being at ‘risk of harm’. GP practices are being closed by the CQC based on this perceived ‘risk of harm’.

You have to continually run the searches and you have to chase the patients who need monitoring. Keep records of your audits and your progress through them.

Create a protocol

You must have a protocol for each search area which sets out what to do for the patients who need monitoring. The areas are DMARDS, High Risk Medicines, MHRA Alerts, Missed Diagnoses, Medicines Usage, Medication Reviews and Long-Term Conditions. The protocol needs to clearly set out the communication steps that staff must take, the relevant time periods and, lastly, the escalation process.

For example, patients on DMARDS will be contacted via text, email, letter and lastly phone call as soon as three months have passed. After four months have passed, a clinician will risk-assess the patient and either shortscript them or record the reason as to why they have not shortscripted them. After five months have passed, a clinician will either end the prescription or record the reason why they have not ended the prescription.

Follow your protocol 

This may seem obvious, but if the CQC find patients who have passed the monitoring guideline time period and there is no evidence/record of communication, shortscripting or risk assessment, your protocol will be viewed as ineffective. If your protocol is ineffective then any patients who are at ‘risk of harm’ will be used as evidence to demonstrate that your practice is unsafe, regardless of your protocols.

If you’re inspected before you’re able to put this work in place, the best response you can produce after a CQC inspection is a detailed action plan setting out your protocol and expected time period to review every patient who is at ‘risk of harm’.

In the future, these searches will be carried out without warning or notice by the CQC. Data on systems such as EMIS, TPP SystmOne and Vision is going to be opened to NHSE and the CQC. So, it’s vital to have a pharmacist or in-house specialist running the Ardens searches continually, along with a strong protocol that is followed by clinicians.

Hop over the CQC section on the forum to share your experiences of searches here.

Useful resources:

The CQC Handbook [PLUS]
Preparing your team for a CQC inspection [PLUS]

Practice Index Training:

• Preparing for a CQC inspection
  Being CQC ready
  How they monitor and inspect general practice including evidence gathering

Learning Package:

• CQC Masterclass
  CQC for all staff