You will have seen previous blogs and posts in the forum advising that the CQC are exchanging 150 key lines of enquiry (KLOEs) for 34 Quality Statements (QSs). This is obviously frustrating for all those Practice Managers who have just finished memorising the 150 KLOEs and aligning evidence to them all! But what does this actually mean for practices from an inspection perspective?

Well, you’ll be glad to know, it doesn’t actually change anything at all. Relieved, confused or perhaps surprised?

The only rules or guidelines that matter are the regulations. The KLOEs and QSs are just the CQC’s way of translating the regulations and associated legislation into guidelines that the public can read without requiring a law degree.

No practice has ever received a warning notice or proposal to cancel from the CQC which quoted the KLOEs. All enforcement activity or scary letters from the CQC quote and rely on the regulations set out by the Health and Social Care Act 2008 and/or Care Quality Commission Regulations 2009. These ‘delightful’ pieces of legislation can only be altered through parliament.

The QSs don’t tell you what to include in your recruitment records, which training courses are mandatory, or that you have to have a PPG. They don’t even state what safeguarding arrangements you need to have in place – despite the fact that the CQC have very specific expectations of what all practices MUST have within these areas. Two people could reach very different conclusions about what the QSs require, based on their vague, aspirational wording.

For example, the QS that refers to the Ardens searches under ‘Effective’ states:

We plan and deliver people’s care and treatment with them, including what is important and matters to them. We do this in line with legislation and current evidence-based good practice and standards. 

There’s no mention of medication reviews, long-term disease management or high-risk medicine monitoring. All of these areas are inspected using specific guidance set by NICE or the CQC themselves. If a practice tried to prepare for a CQC inspection by simply using the QSs, it’s highly unlikely they’d tick all the boxes that are inspected. So then, what is the best way of keeping up to date with CQC compliance?

The prospective evidence categories have not yet been fully established, utilised or tested, so these can’t be used or relied upon when preparing for an inspection. The CQC website does provide case studies of inadequate inspection findings. However, these case studies are again disappointingly vague, and they don’t provide practices with a clear list, structure to follow, or comprehensive explanation.

Is anyone else thinking they’ve been set up to fail?

Thankfully, there’s no need to hit the panic button just yet as Practice Index is here to help. How? Well, we offer CQC virtual training sessions through Practice Index Training which focus on CQC evidence tables. The evidence tables not only set out specific questions within each area, but they also include detailed information when a service has failed to meet regulations. So, whilst the QSs can provide some light bedtime reading, it’s recommended that the most recently published evidence tables on the CQC website are the best way to comprehend the many areas that are, and will always be, inspected by the CQC.

Whenever we talk about the CQC, there’s always a common theme (steady now!) and that is evidence. You must provide evidence to demonstrate your compliance with the regulations; but how do you do this? One way is to use CQC Manager, which is part of the Compliance Package on the HUB, as this is an ideal way to effectively collate and present all the evidence required for the CQC in one central and secure place.

Therefore, whilst there’s more change to come, we know what me must do to prepare for the changes and align our evidence accordingly, so that we’re fully prepared for an inspection, be it remote or on-site.

Until the next time.