- they have “sufficient numbers of suitably qualified, competent, skilled and experienced persons”
- their staff receive “appropriate support, training, professional development, supervision and appraisal as is necessary to enable them to carry out the duties they are employed to perform”
This means that the integrity of your HR system, your policies and procedures, will form part of a CQC inspection.
Whilst the CQC is not expecting practices to use a specific format, they are expecting to see an up-to date, clear robust and efficient HR system, which reflects and records what you do. So what will the CQC be expecting from your HR system?
(1) Clear policies and procedures which are regularly reviewed
Remember that the CQC will be looking at the quality and effectiveness of your key HR policies and procedures.
It all starts with having clear and up to date policies and procedures which are easy to use, accessible and are regularly reviewed. However, not only do those policies and procedures need to be up-to-date you need to prove how and when you have reviewed them.
(2) Doing what you say you will
It’s not just about having superb policies – you need to prove you follow and comply with them from the time they are put in place. So, for example, you’ll need to follow and record your compliance with your recruitment policy to show how you recruit and vet new staff before they start work.
Doing this also protects the practice generally by showing consistency and fairness.
(3) Communicating the policies and procedures
You must be able to effectively communicate your HR policies and procedures to your staff. This means that ensuring that members of your team are able to access a staff handbook is insufficient.
Effective communication means communicating in such a way that your staff are:
- aware of the HR policies and procedure and
- understand them and
- are able to follow them
Start as you mean to go on with a carefully thought out induction process and ensure that you have a system which regularly updates staff both by way of:
- reminder, reinforcing what your HR policies and procedure are and
- updating, as and when you make changes
The CQC will also consider how well you:
- listen to
- respond to
- learn from
concerns which are raised by staff.
(4) Clear, secure and safe Records
Proving what you do means having clear and accessible records. So, for example, when you review a policy you need to have a written record of every stage from the decision to review (why and when) to how you communicated those changes to staff.
Your HR system and corresponding data must be carefully used and comply with the relevant data protection legislation.