The Care Quality Commission (CQC) – What You Need to Know
In advance of the new Care Quality Commission (CQC) quality ratings for independent doctor and clinic services coming into force this month, what lessons can be learned from the recent CQC report on the state of care in independent doctor and clinic services?
From April 2019, the CQC will be awarding quality ratings to independent doctor and clinic services, to bring their approach in line with the other services they regulate. These ratings will need to be clearly displayed on the relevant premises. This is an important development that those that run independent and private services need to be aware of; regulatory compliance is crucial not only from a patient safety perspective, but also now more than ever, from a commercial perspective, as there is an inevitable reputational risk associated with poor ratings.
The recently published CQC report on the state of care in independent doctor and clinic services, provides these businesses with a useful checklist of areas to focus on when reviewing compliance with the CQC regulations.
The recently published CQC report considers the state of care in independent doctor and clinic services providing primary medical care. This includes private GP practices, travel, slimming, circumcision and allergy clinics and clinicians registered with the GMC who provide consultations and/or treatments outside of the NHS sector.
The report is based on the analysis of 85 inspection reports carried out between January 2017 and October 2018 and on the views of CQC’s senior inspection staff. In the course of the CQC’s inspections, services were assessed against the CQC’s key five questions: namely whether services were safe, effective, caring, responsive and well-led.
Whilst the CQC’s report shows that many independent doctor and clinic services were meeting the requirements of the regulations, a number of services were not delivering services to the standards required by the CQC.
The CQC’s report identifies several key issues that were common to most of the services inspected:
On the first inspection, just under half of independent doctor services and slimming clinics failed to provide safe care in accordance with relevant regulations, but that most of them had improved upon re-inspection. Some of the issues identified included limited clinical oversight and monitoring, lack of awareness of safeguarding and establishing patients’ identity, issues with managing patients’ care records and not sharing information with patients’ NHS general practitioner in accordance with the GMC guidance. The CQC found issues with prescribing medicine outside of evidence-based guidance and licenced use, issues with medicines management as well as issues with identity checks in the context of recruitment.
A quarter of services assessed on the first inspection were not providing effective care in accordance with the relevant regulations. The main concerns were found in relation to not keeping up to date with and following current evidence-based practice and guidance, inappropriate prescribing, not gaining appropriate consent and not making appropriate referrals. The CQC also found concerns with regards to a lack of formal clinical leadership and support.
There were very few concerns in this key area. In general, inspection reports analysed showed that the privacy and dignity of patients was respected and that services enjoyed a high level of patient satisfaction. The CQC also found that services that asked for feedback following each consultation used that feedback to make improvements. The report did identify services requiring improvement in the area of patient privacy and confidentiality, but the numbers of those were small.
Services were generally responsive, although a small number of services were found to require improvements. Issues that needed addressing included: a lack of adequate information for patients on making a complaint, not arranging a formal translation service for foreign language speaking patients and not providing adequate accessibility for patients with protected equality characteristics.
Some services were not well-led in accordance with the relevant regulations on their first inspection, but found some improvements on re-inspection. The main issues that required addressing included ineffective overall governance framework and quality monitoring systems, out of date policies and procedures, ineffective risk management arrangements, and ineffective information sharing platforms.
We assist care homes and independent clinics with their regulatory affairs, including with the CQC regime. This includes dealing with challenges to ratings, complaints about the manner in which an inspection has been carried out, proposed enforcement action and adverse inspection reports.
When concerns are identified about the services that private and independent doctors provide, the CQC will not hesitate to take prompt action to ensure patient safety. It is therefore crucial for service providers to address, without delay, any concerns identified in a CQC report. It is equally important for service providers to understand the requirement of on-going compliance with the CQC standards – all registered services are monitored all year round, even after they received an “outstanding” rating. Failure to proactively address issues such as those identified in the recent report, may well lead to adverse ratings.
Ratings may fundamentally change a service user’s view on the care provided by independent doctor and clinic services, as such the CQC’s new approach is not only a fundamental change in terms of regulation, but it will also have a commercial effect on a business.
 The Care Quality Commission (CQC) is the independent regulator of health and social care in England. It monitors, inspects and regulates health and social care services, including independent doctor and clinic services. The CQC applies the same model to all services it regulates: registration, on-going monitoring, reporting on findings and taking action where standards fall below the required threshold.
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