In the middle of March 2018, the CQC published revised guidance detailing the way it intends to inspect GP Practices, updating its publication from October 2017.

The guidance shared details on how the CQC intends to work with the Annual Provider Information and the review of practices with ‘good’ and ‘outstanding’ ratings – which covers the vast majority of practices. It also provided updated guidance on inspections, evidence and how they intend to inspect practices which did not fall into the previous ratings. As a guide for the future, the document reflected what CQC Inspectors and Specialist Advisors had been briefed about in mid-2017 and put forward no surprises.

Feedback on board

The main impression most of us have gained from the new notes is that the overall process has been streamlined. The good news is that much of the feedback from practices, inspection teams and representative bodies has been taken on board. The intention not to overburden well-performing practices is both pragmatic and reasonable, while still providing enough oversight of how they are functioning.

Additionally, the CQC has accepted there is a need for a more intelligence-driven, targeted and risk-based approach to regulation and also earlier this year undertook a consultation covering the perception of consistency in inspections – an issue that most GP practices, as well as inspection teams, would agree needs discussion.

One of the hot topics for practices is the Provider Information Collection Tool (PICT). There has clearly been an intention to get this right – both in terms of collection of the data which should not be too onerous for practices and also collecting the data that gives a meaningful picture of how a practice is performing. Interim information, which practices who are being inspected currently have to submit, reflect more on the old system than the new, and we can expect the annual online submission to be finalised later in the year.

The guidance does indicate that the annual information submission will be the only data that a good/outstanding practice will be required to provide. It is currently being ‘road-tested’ with practice managers who are specialist advisors to ensure it is fit for purpose once completed.

Another acronym

As with most things, there is another acronym that practices will need to be aware of – the PIR (or Practice Information Request).

This will mean more to a practice with any rating less than ‘good’ and is intended to provide additional information such as staffing issues, your monitoring and clinical audit processes and how you deal with complaints and incidents. Once you have received a PIR you will have five days to respond. Perhaps most notably, receiving a request will invariably indicate that you are receiving an on-site inspection and can expect any actions or requirements made in your last CQC Inspection Report to be checked to ensure they have been done (or that you have implemented an action plan and are not prevaricating).

“Look at all this additional work each year!” some PMs may say. The response will always be that a good and safe practice should consistently be monitoring how it works if for no other reason than to minimise risks to patients, staff and the practice itself. Setting up the necessary system to generate the data should only be an initial investment in time for the first year, once the data that CQC ask for is known. How well a practice updates that internal data and monitors it throughout the year will determine how long the annual return should take.

Reduced frequency

For many practices, the PICT will be their first and only encounter with the Inspection system for the next four to five years as the intention is to only visit 20% of good/outstanding practices annually. That said, it doesn’t mean a good practice will not receive a comprehensive inspection visit out of turn, should CQC monitoring systems flag up a problem – either through information received directly from patients or CCG etc. or from the data provided through the PICT.

The word of warning here however is not to misrepresent the practice position in the Annual Return. You can be certain that what you provide on an annual basis will be checked up on when you do have your scheduled on-site Inspection.

A named inspector

The allocation of a named Inspector to practices on a geographical basis will serve to provide a point of reference for all queries, and establish a working relationship that should ease the inspection process considerably.

If you do not yet know who your inspector is then making that enquiry with the CQC would be a priority.

Revised KLOEs

The Key Lines of Enquiry (KLOES) have been changed in varying degrees in respect of GP practices and it is always good to use them as the basis for your own ongoing monitoring of service. The 50+ page document which details the changes can be found here. The amount of revision is clearly indicated in that document.

Much of the change amounts to rewording and clarification, however there are eight `new` KLOEs in Safe; five new in Effective; three in Caring; six in Responsive but, good news for PMs, nothing new in Well Led.

Looking at the new indicators it’s apparent that they generally reflect what should be done already, and what most practices would consider good practice. However, the degree of change that you perceive that they have introduced may not be the same for everyone. Whether a practice can demonstrate them is always another matter but, as the new KLOES guidance is very detailed, time set aside now to review them will save time and stress in the future.

Consistency

The final issue to consider – one that PMs will agree is much needed – is that of consistency.

Inspection teams work to a template and some of the issues that generate the questions are cross-referenced between those used for the patients, the practice manager, practice staff and clinicians. Consistency is not just a matter for the inspection team, especially when different and conflicting answers are given to different team members!

The developing inspection system will, in time, result in a developing consistency of approach. The team learns with the more inspections they undertake and the practice of not using the same members together on each occasion assists in sharing knowledge and methodology. It will be interesting to see the results of the consultation exercise in due course but it is good to note that it is something that has been taken on board and is being worked on.

The CQC and the inspection process is certainly here to stay. The NHS is a developing entity and there will always be changes brought in and then discarded and we can take QOF as a possible example!

It only remains to return to what should be the aim of all practices – and that is to provide a safe, responsive, effective, caring and well-led service to its patients. But haven`t we heard that aspiration somewhere before?!

Key takeaways

• Good and outstanding practices should have a much less onerous inspection programme.
• The annual PICT information submission will be the only data that a good/outstanding practice will be required to provide.
• Receiving a PIR request will invariably indicate that you are receiving an on-site inspection.
• The intention is for inspectors to only visit 20% of good/outstanding practices annually.
• Make sure you find out who your allocated inspector is.
• Take time now to research the revised KLOEs and what they mean for your practice – and don’t worry – most are just good practice

Helpful document for your CQC inspection: CQC guidance

What are your views on the above? Will it help? Or are inspections just another burden on the time of practice managers? Let us know by commenting below or take it to the Practice Index forum.