The inspector’s call is very different now to what it was pre-COVID. Gone are the days when CQC inspectors turned up at the door and spent the day, or a couple of days, looking at various aspects of a service.
It has now become the norm for the CQC to carry out the majority of its inspection activity off-site and only visiting a service for a short period if they deem it necessary. Some may prefer this new approach to inspections. However, regardless of preference, remote inspections do come with challenges.
This article explores some of those challenges and provides suggestions on how to overcome these.
Having observed an inspection of a GP practice while working for the CQC I can see the value of on-site inspections. I can see the difficulties providers would face showcasing good practice, or simply explaining how things are carried out within the service, to an inspector on the phone or Microsoft Teams rather than in-person.
With on-site inspections, inspectors can speak to a random selection of patients after their consultation. They can ask in-the-moment questions of staff and are able to seek clarity on processes and procedures there and then if necessary. As an observer, on-site inspections allowed the inspector to gain a sense of the service, which was more than the raw data – and much needed to produce a fair and balanced inspection report.
What we appear to be seeing now is a process in which intelligence, data, complaints and concerns often lead inspectors to draw negative impressions of a service and the short visit, if there is one, is used to verify and often reinforce the negative view held.
This can result in good practice being missed, disproportionate conclusions being drawn within inspection reports and a decline in ratings.
Overcoming the challenges
Remote inspections began with the CQC’s launch of its transitional regulatory approach (TRA), where it embarked on 'intelligence-led' regulation, with the aim of making inspections 'less of an event' for providers.
Remote monitoring involves the CQC reviewing the information it holds about the service. Inspectors will look at CCG information, previous inspection reports, feedback about the service, as well as complaints and whistleblowing. CQC experts by experience may also contact your patients.
Due to the nature of remote inspections, the CQC cannot or may not query the legitimacy of or motivations behind negative feedback. At Ridouts, we have seen many inspection reports where people’s statements have been taken at face value with no corroboration. This means it is vital that providers do their best to explain events from the practice’s perspective.
The remote inspection will often involve a conversation online or by telephone with the practice. It is important to be familiar with the CQC’s monitoring questions which are on their website.
It is also important that providers are prepared to send information to the CQC at very short notice as inspectors will often ask for details to be sent to them within 24 hours. This means practices need to be organised, know where to locate information and be able to present information in a clear way.
As opposed to sending the CQC raw data, providers should take time to write and explain to the CQC what the information means.
If problems are identified during the inspection, it is better that the provider explains them to the CQC, rather than simply allow the regulator to draw its own conclusions. In addition, the provider should explain to the CQC what is being done to address any problem.
The same goes for complaints – practices should inform the inspector of their view to help ensure the inspector receives a fair and balanced picture of events.
Ridouts have experience of services that have been inspected entirely remotely, which providers have felt has led to inaccurate inspection reports. In such instances, if providers would prefer an on-site inspection, they should insist on one; it is not guaranteed the CQC will listen but it is worth a try.
For practices whose services are inspected, and are unhappy with their draft report, Ridouts can support you through the factual accuracy process. Providers should check and challenge the completeness of the information that the CQC has used to reach its decision and ratings.
- If you require assistance or advice responding to the CQC, you can contact Ridouts at firstname.lastname@example.org or by calling 0207 317 0340.
Ridouts Professional Services PLC
Ridouts is a law firm that only acts for care providers. We provide legal, operational and strategic advice when providers are faced with matters that could negatively impact their businesses, such as poor CQC inspections and enforcement action. www.ridout-law.com
This article is funded by Ridouts for GP Connect