By now, it’s safe to assume that all practice managers know what a KLOE is. However, when it comes to dealing with the CQC, the real test is whether what you believe it means corresponds with what your CQC Inspection Team believes it is. From experience, the gap between the two can be a significant one, a gap that this article – and the series that follows – will endeavour to bridge.
Experience and anecdotal evidence dictates that the several members of an Inspection Team can have different views and as the writer is neither an Inspector nor a GP, you will soon realise that the approach here will generally be from the direction of practice Management.
What a KLOE is and isn’t
An appropriate starting point is probably to say what a KLOE is not. Well it is not a radio station in Kansas, or a manufacturer of optical sensors in Montpellier and neither is it the given name of a member of the Kardashian family (isn`t the Internet a wealth of information!). In the context of this series of articles it relates to Key Lines of Enquiry – or those broad headings against which the CQC will assess your practice to ensure you meet the necessary Fundamental Standards and which we will need to look at in turn and some in depth.
Newly appointed practice managers may not be familiar with the concept of inspection against a standard set of criteria. However, this has been increasingly normal both in public services and also some private companies for many years. It has often appeared in the guise of ‘performance indicators’ so makes sense to consider KLOEs as indicators of how a practice is performing in the five groupings that the CQC has set out. Grouping those indicators based on national standards into an understandable structure was a great start, especially as they are used with a degree of commonality across the whole of the health and social care economies.
The five areas are: Well Led, Responsive, Safe, Effective and Caring and over this series of articles the intention is to cover them by looking at the aspects which seem to be the least-understood and which take the most explanation or which give the most cause for discussion during inspections. It is also important that practice managers know where to conduct their own research into what constitutes a standard, a KLOE and the guidance that underpins them, so it will endeavour to point Practice Index readers to the web-based resources at the start.
New inspection processes
It perhaps only remains to briefly go through the new inspection process as we currently understand it to be, although at the time of writing the exact details of some points have not been fully developed and communicated. It reflects the work of the Regulating General Practice Programme Board (RGPPB) in establishing a shared view and understanding of quality for general practice,
Streamlining data collection from practices and streamlining processes and requests. More information can be found here.
The detailed explanation of how the CQC monitors, inspects and regulates GP practices appears in a document produced in March 2018. The process rests on several factors such as the rating your practice has received in the past, the intelligence that CQC gathers about how the practice is performing (including for some practices that do not give cause for concern an annual self-reporting system in place of a Team visit) and also a commitment to carry out an inspection visit to 20% of practices every year.
Practices will be familiar with the `six population groups` (namely Older people; People with long-term conditions; Families, children and young people; Working age people; People experiencing poor mental health and People whose circumstances may make them vulnerable) and these will continue to be looked at and reported upon under those headings during an inspection.
Good or outstanding practices will be asked to complete an online return of practice activity each year in place of an onsite visit (remembering that 20% of practices each year will still get a visit) but practices requiring improvement or inadequate will receive a visit in 12 months or six months respectively. These practices will need to provide information relative to their situation and may be comprehensively inspected or have a focused inspection depending on circumstances.
KLOEs and standards
Having mentioned the fundamental standards that underpin the KLOEs, it only now remains to highlight individual KLOEs to briefly remind everyone what those standards are:
- The patient must receive care that is appropriate and conforms to their wishes
- The patient must be treated with dignity and respect at all times
- Consent is sought and given before any care or treatment is undertaken.
- Treatment given must be safe and free from avoidable harm and delivered by properly trained and skilled staff
- Patients are protected from harm, abuse or neglect
- Equipment must be safe and properly used
- Complaints can be freely made, properly investigated, lessons learned and responded to with openness and transparency
- Quality and safety must be properly monitored, lessons learned and effectively governed
- Staff must be properly recruited with the right skills and checks to ensure safety, trained and supervised
A major issue throughout all of the KLOEs is that of risk. Risk to patients, risk to staff and risk to the continued existence of the practice and its finances are important areas to consider.
Inspections will always ask if a particular issue has been risk-assessed and often there has been no formal or documented review of the implications of a decision made. Even if that decision comes down to something that the inspection team members would not do themselves, the fact of an assessment having been made and documented, practice choice would be respected in most cases.
One source of reference not mentioned so far is Nigel’s Surgery. It has been available to practices on the CQC website almost from day one of GP inspections and is the source that most inspection staff turn to first. It cannot be recommended too highly for practice managers – along with the CQC guidance document by Practice Index of course!
Across a series of six further articles over the coming weeks, we’ll be looking at the five KLOEs in more detail.
Also, don’t miss our PM’s guide to the developing CQC inspection regime – all you need to know about the new-look inspections.
Catch up with the rest of “The inspection insider” series here.
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