After almost five years of the new dental compliance inspection, the Care Quality Commission (CQC) has settled into a standard format, giving us plenty of useful insight into how CQC inspections are carried out, what areas are consistently being looked at, and where dental practices are most often failing.
On the whole, the CQC provides dental practices with two-week’s notice of an inspection to allow providers a grace period to prepare and sort out any loose ends. They do not see their role as being there to catch you out, rather to encourage improvement instead.
Alex O’Neill, CODE’s Head of Compliance, offers some vital insight
Types of CQC inspection
- Routine CQC inspections – Carried out on 10% of dental practices per region, per year. We recommend expecting a routine inspection around every five years, this should help you to be prepared when the time comes.
- Focused CQC inspections – Carried out when a practice has failed a routine CQC inspection. Alternatively, this type of inspection can happen following a problem, such as whistleblowing or a patient concern. This would be the worst-case scenario as the CQC can arrive unannounced, without giving you the usual two-week’s notice that would normally be provided.
Manage your public image
Prior to their visit, a CQC inspector will gather as much information about your dental practice as possible, from any source available to them. This could be from Google, NHS.net, online reviews, etc.
This allows them the opportunity to see whether a dental practice has been actively looking for and improving from feedback, so one of the first things you can do to prepare is regularly check for reviews from patients and respond effectively.
From this, the CQC can also start to look for any relevant trends. If there are comments that repeatedly say, for example, the dental receptionist is rude and unfriendly, you can be certain that one of the first things they will ask you is what you’ve done to manage this situation.
From feedback and reviews, you can look for any trends for yourself and manage issues accordingly before your CQC inspection. A key tip here is to treat a bad online review in the same way you would a complaint, logging it, investigating and then improving.
Check your previous CQC inspection report
A significant number of pre-2015 reports, even from practices that passed, will contain the phrase ‘the provider may wish to note that…’ These are the areas where the CQC has noticed a small issue and you can guarantee an inspector will check to see whether improvements have been made since the last visit.
My top tip is to search your report for the phrase ‘the provider may’ and highlight areas that you can flag up to be checked and improved, prior to an upcoming CQC inspection.
Once you receive the two-week’s notice of a CQC inspection, my advice would be to carry out a gap analysis.
The first thing you require for this is a benchmark of where your compliance should be compared to where it currently is. This can come from one of two places, either internal knowledge (e.g. from an exceptional team member) or external expertise, such as a system like iComply. Finally, if neither option is available to the practice, you can call an expert in.
Following your gap analysis, you should be able to generate an action plan that you can then begin to work through before your CQC inspection to ensure you have done as much as you can before the visit.
Keep hold of this action plan and discuss it with the CQC inspector when they come in – it shows that you are knowledgeable and on top of what you need to do.
These are living documents that your practice follows and runs by. They are not just papers that you update each year with a fresh date and never look at again.
It is very easy for a CQC inspector to see if you are not following your policies, so familiarise yourself with them to ensure that the practice and team are following what your policies say. If not, edit them so that they are in line with your systems and procedures.
Quite often, discrepancies are discovered within safety alerts and recruitment policies. This is because they are quite prescriptive in terms of the procedure outlined, so do check to make sure you are following them correctly and fill the gaps where required.
Audits and follow ups
Prior to a CQC inspection, check that you have followed up on any audits, patient surveys, risk assessments, complaints, events etc. This usually involves creating a summary of your findings and a dated action plan, then signing off and resolving outstanding actions (which could involve holding meetings/taking minutes etc.).
Be ready to show a clear paper trail of why and how you improved. Always remember that the goal with an audit is to find issues and improve (not to score 100%).
The CQC inspectors are human beings who don’t make the regulations. In the same way that you (hopefully!) wouldn’t debate speeding laws with the police when pulled over, please avoid arguing with an inspector.
Most dental practices have that one dentist who would love the opportunity to argue HTM 01-05, for example. Perhaps make sure this team member has the day off when an inspector calls!
As Yoda says, ‘Do or do not, there is no try’, if a CQC inspector asks how something was handled never use the words ‘try’ or ‘should’.
The CQC wants to know what you did or do, your intentions, however well meant, aren’t facts. It’s very easy to tell whether something has or has not been done just by the language used – words like ‘try’ or ‘should’ are dead giveaways and can display a lack of competency from the manager.
The real crux of the matter is this; a compliant practice is one that successfully follows and meets the regulations, by correctly carrying out certain tasks every day.
This is not something that can be achieved in two weeks prior to inspection, compliance is something that must be worked on at all times.
Having a governance system, such as iComply, in place can help you to effectively manage this to cover all of the required areas across a 12-month period.
- Talk positively about compliance, this will help to create a better team attitude and atmosphere
- Ensure your complaints procedure, fee list and GDC Standards are displayed. These are basics
- Overall cleanliness/tidiness is vital as it provides a first impression of your practice. Check that the noticeboard doesn’t look scruffy and staff uniforms are clean and pressed
- Have a clear and well-organised file set that you can easily refer to
CQC inspection checklist
- Carry out a gap analysis
- Take care of your easy wins
- Read your last report
- Review all feedback, audits, risk assessments and action plans
- Log any missing compliance on a master spreadsheet and deal with as much as you can. Show the inspector this plan when they come in and discuss it with them – it shows that you are knowledgeable and on top of what you need to do.
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