Author: Alex O’Neill – Head of Compliance
Many members have asked us what is changing this year in regard to CQC inspections and whether or not we think practices will be rated in the future. In this article I’d like to explore what we know for certain and what we think could happen regarding ratings. In an upcoming article I’ll also be dissecting what the new strategy from the CQC potentially means for the profession as a whole and for dental inspections specifically.
Last year, due to the pandemic, the CQC stopped the routine inspection of dental practices and only ‘crossed the threshold’ where they felt patients were potentially at risk. In October the ‘Transitional Monitoring Approach’ (TMA) was introduced, with the CQC aiming to perform 1500 TMA calls between October 2020 and May 2021. This was significantly more calls than the CQC would normally perform inspections, so it will be interesting if they publish a summary of what they found at some point in the future. As always, the iComply team were the first to provide support to practices, producing a 20-page guide to the assessment which has helped hundreds of our members.
Since October the CQC have engaged with the profession in a series of ‘strategy engagement sessions’, have consulted with the public over their proposed strategy and have given an interim update on their regulatory approach.
I reached out to the CQC regarding feedback from the engagement sessions, asking if the feedback would be published and was helpfully informed that their learning from the sessions will feed into the emerging strategy, that methodology changes have yet to be decided and that any proposed changes would be discussed with the profession before implementation. It was very apparent that the CQC appreciate that operating a practice in 2021 has considerable stresses and are not intending any significant changes in the immediate future.
My general interpretation, based on all the information available, is that we’re going to see some small changes soon, some bigger proposed changes later and then further consultation with the profession before implementation. The CQC’s strategy has only recently been finalised and it’s important to keep in mind that strategy generally defines organisational direction (phase 1) that once agreed needs translating by operational teams (the inspectors etc.) into tangible tactics and actions to align procedures and approaches to the new direction (phase 2).
This means I’d be very wary of anyone telling you right now that they know how and why the CQC dental inspections are going to change, or selling a course to teach you it, because apart from a few ‘knowns’ outlined below, that can be seen as initial small changes, until the CQC publish sector specific information, anything else is just intelligent guess work.
Update on CQC’s regulatory approach
In a statement to the profession in March, the CQC provided an update to its regulatory approach. At the start of the pandemic, they paused routine inspections and focused their activity where there was a risk to people’s safety. As the recovery continues, the CQC are beginning to undertake further inspections.
For dental practices, in addition to undertaking inspection activity where there is a clear risk to safety, the CQC will:
- resume inspections of independent primary care providers, focusing on high/medium risk providers that have never been inspected or that were inspected but not rated
- inspect services that are newly registered and have not been inspected during the 12 months since registration, or during the three months since registration for online services
- commence a programme of focused inspections for oral health providers exploring an increased use of technology
- continue to develop the transitional monitoring approach
What this means for the profession
The short version is that registration inspections have started again and if you have never had an inspection then you should expect one in the not too distant future, though this could be remote and using technology.
It looks like all practices should expect an increased frequency of ‘touch points’ from their local inspector with remote assessments that will be shorter and more focused.
These assessments will most likely focus on safety, access, infection control and leadership, under the Safe, Effective and Well-led KLOEs . It will be interesting to see how this develops (future ‘phase 2’ changes) and whether or not we will have to start completing annual information returns (other sectors already do this routinely for the CQC). If this happens then I will make sure that iComply members will be able to easily pull reports from the system to meet the information requirements from the CQC.
Questions the CQC asked the profession and the response:
In late October 2020 the CQC hosted a number of ‘strategy engagement sessions’ and the team here at Agilio attended multiple sessions, including those aimed at providers and those aimed at compliance professionals. The findings from these sessions have yet to be published by the CQC. As mentioned above the CQC have told us that they will use this learning to help develop their strategy and will bring any arising methodology changes to the profession before implementation.
On these calls three questions were asked and feedback provided that seemed generally consistent across all calls:
- Should CQC limit face to face inspections to practices where there are concerns? – The general feedback we observed to this question was that the profession felt that a practice could have poor compliance and this would not flag to the CQC unless they performed on site inspections. Also, that remote inspections would not necessarily always pick up on practice level issues that an inspector would observe when on site
- What do you think about more regular calls from CQC?– The general feedback we observed was that the profession felt more regular calls would be beneficial, but not at the expense of fewer onsite inspections
- Would rating dental services have any benefit? – The general feedback we observed on this question was that the profession were very clearly against introducing ratings and could not see any clear benefit
I think the CQC should be commended for all the hard work they have done since 2015 to both engage with, and earn the respect of, the profession. Pre 2015 we became very frustrated with ill-informed inspectors judging the quality of our practices and in generally the CQC were not looked upon favourably. I feel that in the last 5 years with well-trained inspectors, alongside an open and fair approach this view has changed radically and most providers feel they are doing a good job in protecting patients. This does not mean that there aren’t still some issues, but as you’ll see in my next article the CQC is trying to address some of the key criticisms it receives through its new strategy.
Do you think practices will get rated?
At Agilio we think that ratings are unlikely at this point, but are perhaps inevitable due to dental providers being the only type to not currently be rated. The introduction of ratings also has the potential to significantly upset the profession for multiple reasons.
In order to rate practices the CQC would have to do certain things. To keep ratings current and accurate they would have to assess significantly more that the historic 10% per year (2015-2020). The TMR has shown what can be achieved numbers wise so these assessments could be remote, shorter and more focused, say double the number of inspections at half the length.
However, if you’re focused on something in particular then could the inspection be said to be ‘comprehensive’ enough to rate a practice and if the assessment was remote then it would almost definitely be more difficult for inspectors to identify areas of ‘non-compliance’. The methodology may also have to change to reduce the number of areas assessed and maybe a reframing of what is considered ‘critical’ for compliance would benefit both the inspectors and the profession. The emerging strategy hints at this somewhat.
Either way it seems obvious that rating practices will simply require more people and time, meaning an increase in costs to the CQC, and as the dental team runs a balanced book this would mean most likely not an insignificant fee increase for registered dental providers.
As I indicated above the overwhelming consensus on the calls we attended was against rating the profession and therefore increasing costs for this reason could potentially undo the fantastic work the CQC have performed over the last 5 years to win the respect of the profession. We are watching closely for developments in this area.
So what happens next?
In their recent strategy announcement session Ian Trenholm, CQC Chief Executive, outlined their priorities for the next 12 months which included further development on how they monitor risk, research/engagement on ‘safety’ and testing of a new assessment framework. The CQC were candid that some of the ‘how’ questions now being asked in relation to the strategy would be explored collaboratively as part of the next stage.
Now that the strategy has been formalised and officially announced I believe the inspection teams at the CQC will start to develop on potentially pre-existing draft plans to initiate what I defined above as ‘Phase 2’, which will most likely involve draft methodology changes that the profession are then consulted on. The information we have from the consultation documents outlines key themes and as you will see in my next article you can use intelligent guesswork to predict what these changes could be (however, I stress that these are just predictions). For example, it seems that the CQC will most likely introduce annual returns at some point (though I have been saying this for about 5 years, so am potentially biased), that we may get a reduction in compliance areas they feel are ‘critical’, that we may have an increase in guidance from the CQC amongst other things. I hope you read the next article to find out more about what we’re thinking here at Agilio.
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