Preparing for CQC inspection Deborah Sterry

Presentation copyright: Deborah Sterry Social Care Regulation Consultant and David Finney Associates 

Deborah Sterry 

Social Care Regulation Consultant 

Preparing for CQC inspection 

Deborah Sterry, Independent Social Care 

Regulation Consultant – June 2012 

CQC’s changing role 

The Government has strengthened our role to make 

sure we focus on our core business: to inspect 

providers to make sure that the essential standards 

are being met, and to take swift action when they are 

not 

CQC consultation on proposed changes to their 

judgement framework and enforcement policy – 

September 2011 

Copyright: Deborah Sterry Social Care Regulation Consultant and 

David Finney Associates 

What are the key changes? 

Focus of inspection: 

� to identify areas of non-compliance 

Judgement either: 

� Compliant 

� Non-compliant 

Not required: 

� CQC will no longer ask for ‘improvement’ actions 

� PCA – not required before visit – but maybe after 



Today 

� Provide you with an overview of the changes to 

CQC’s regulatory model 

� Look at why some of these changes have been 

made 

� Consider what might assure CQC that compliance is 

achieved 

� Understand how to ‘think like an inspector’ 




Frequency of inspection: 

� Minimum once a year 

� CQC will re-inspect services who fail to meet essential standards 

Types of inspection: 

� Planned - covers key outcomes, unless site visit, or information 

held by CQC, identifies issues in other outcome areas 

� Responsive – these are carried out when concerns are raised 

about compliance with the standards 

� Thematic - focussed on specific outcome areas and/or type of 

service; report to provider and findings contribute to a national 

report 


All inspections are unannounced David Finney unless Associates CQC believes there is a 

very good reason for prior notice to be given 


More targeted inspection: 

� CQC will continually review all 16 core 

standards through analysis of information held 

� Inspect a smaller number of standards 

� Minimum of 5 (1 standard from each chapter 

heading in CQC Essential Standards of Quality 

and Safety) 



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Key Outcomes 

� Involvement and Information – Outcome 1 

� Care & Welfare – Outcome 4 

� Safeguarding – Outcome 7 

� Staffing – Outcomes 12,13 & 14 

� Quality Monitoring – Outcome 16 



Note: If several 

instances of noncompliance 

are 

becoming apparent 

and they suggest 

governance issues, 

you should include 

Regulation 10 

(outcome 16) in your 

inspection 

CQC Judgement 

Framework 


Making judgements: 

Once non-compliant judgement made, inspector decides 

whether impact is: 

� Minor – poor care that impacts on health, safety or welfare or 

there was a risk of this happening – the matter can be 

managed or resolved quickly 

� Moderate – poor care that had a significant impact on health, 

safety or welfare or there was a risk of this happening – the 

matter may need to be resolved quickly 

� Major – poor care that had a serious current or long-term 

impact on health, safety and welfare, or a risk of this happening 

– the matter needs to be resolved quickly 



Stage 3 – CQC Judgement Framework 

CQC - Regulatory response escalator 

Minor impact 

Compliance 

action 




Making judgements: 

� Prompts at Stage 2 and 3 removed 

� Case studies now on website 







Compliance 

action 

Moderate impact 

Warning notice 

Moderate impact – How CQC decide whether to issue a warning 

notice instead of compliance action: 

• if there urgency for changes to be implement? And 

• if a direct follow up inspection needed? 

CQC Judgement Framework, Apr 2012 



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•Warning notice 

•Penalty notice 

•Simple Caution 

•Prosecution 

Major impact 

Enforcement action 



•Impose, vary, remove 

conditions of registration 

•Suspend registration 

•Cancel registration 


What happens after CQC decide their 

regulatory response? 

� Provider must send CQC an action plan if non 

compliance found (SMART) 

� CQC follow up: 

� desk top review where provision of information gives 

assurance – reserve right to visit if felt necessary 

� by inspection 



Principles of Inspection 

� Outcomes, outcomes, outcomes 

� What is the experience of the service 

user? 

�What does it feel like to receive the care 

�What is the result of the care 

� Can the service ‘demonstrate’ outcomes 

are met? 



What are the proposed changes? 

Enforcement 

� No longer extend timescales for compliance 

� Warning notices – if issued, will be mentioned 

in the report 

� Removed all reference to: 

� Encourage improvement without enforcement 

action 

� Taking into account providers track record 



Let us think like an inspector 



Outcome 4 – care and welfare 

� Inputs – written care plan, reviews, risk assessments 

� Outcome – people experience effective, safe and 

appropriate care that meets their needs and protects 

their rights 

� How? 

� Effective – people have a positive experience of care, 

and “it works for them”. 

� Safe – risks are identified and well managed 

� Appropriate – people have a say in how care is 

delivered, relevant to assessed needs 

� Rights – are identified David and Finney met, Associates 

MCA applied 


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Always ask yourself ......... 



So what will inspectors do? 

Before the visit: 

� plan their visit – look at all the information held 

in the quality and risk profile (Quality and Risk 

Profile - QRP) 

�Use this to identify what they will look at from 

each of the 5 chapter headings in CQC’s 

Essential Standards of Quality and Safety 



What methods will inspectors use? 

Inspectors focus on outcomes and look at 

sources of evidence by: 

� Observing care being delivered 

� Tracking the care of individual service users 

� Talking to 

� residents, relatives and visitors 

� manager and staff 

� Looking at records – care plans, staff records etc 

� Checking policies – usually only if there are 

issues arising 



Examples: 

So what!! 

� we make sure that wherever possible the person is fully 

involved in the assessment and planning process so that 

they are able to tell us what is important to them 

� the outcome we want for people using our service is a 

person centred plan that they are entirely happy with, fully 

respects their rights and clearly sets out the actions needed 

to meet their day to day needs and longer term aspirations. 

To do this we ....... 



So what will inspectors do? 

During the visit: 

� focus on the outcomes that people experience 

� assess the care, treatment and support delivered 

...by the provider 

� establish that people are safe, involved in their 

...care and their views are listened to 

� satisfy themselves that staff have the knowledge, 

...skills and competence to provide good outcomes 

...for people 

� if non-compliance with essential standards of 


...quality and safety is identified David Finney Associates – obtain evidence 

Observation 

� 50% of time observing care process 

� Formal/informal approach 

� To observe the delivery of care 

� Will include what you see, hear and smell 

� Observation must preserve dignity and rights 

� Not all aspects of care can be observed (for 

example, personal care) 

� Should be used with other inspection tools 

(discussion, surveys etc) 



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How can we prepare for an inspection? 



Ask yourselves:- 

Think like an inspector 

“If I spent time observing 

care would I see the 

same things that an 

inspector sees?” 

In practice 

Would our service users, 

staff and visitors tell the 

inspectors what I think 

they would? 



What will inspectors do when they visit? 

Case tracking (care pathway tracking) 

� Used to track the experience of a service 

....user/s across the outcome areas being 

....focussed on 

� Considers the persons journey 

• choosing, using and leaving a service 

� Can identify evidence that will suggest further 

....areas for scrutiny 

� Is used by inspectors to 

• triangulate evidence already held in QRP 

• be more proportionate and target their 



..resources 

CQC observational prompt : 

Observation 

� Outcome 1: Respecting and involving people who use 

services 

� Outcome 4: Care and welfare of people who use 

services 

� Outcome 5: Meeting nutritional needs 

� Outcome 7: Safeguarding people who use services from 

abuse 

� Outcome 9: Management of medicines 

� Outcomes 12, 13 and 14: Staffing and support for 


workers 


What questions could inspectors ask? 

Inspectors will ask people questions – look at key outcome 

areas and think about what those questions will be: 

� can use those potential questions as part of your 

quality monitoring of your services 

� use responses as part of identifying shortfalls 

and any improvements required in the service 

you provide 

� can ensure that staff and service users are able 

to describe the service they give and receive 

� can de-mystify the inspection process for staff 

and service users 



Ask yourselves:- 

In practice 

Could I use a case 

tracking approach as 

part of monitoring 

practice in my service? 



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How can we prepare for an inspection? 

Inspection report 

Ceilidh Road Care Home 

11 Manchester Grove, Princeton, XY9 2BY 

Inspection date 8 April 2012 

Publication May 2012 

We inspected the following standards and this is what we found: 

Respecting and involving people who use � Met this standard 

services (outcome 1) 

Care and welfare of people who use services 

(outcome 4) 

� 

Met this standard 

Safety and suitability of premises (outcome 10) x Action needed 

Supporting workers (outcome 14) x Action needed 

Assessing and monitoring the quality of service 

provision (outcome 16) 

� 

Met this standard 

Regularly review CQC 

reports: they are a 

useful resource: 

� Review your own reports 

�Look at reports for other 

services in your organisation 

�Look at reports for services 

Copyright: Deborah Sterry Social Care Regulation Consultant providing and similar care to you. 


CQC reports – methods used 

What people who use service experienced: 

Inspectors were told: 

� “I am very well looked after” 

� “we are asked what we would like to eat” 

� “really supportive and helpful, good sense of 

humour and we can laugh with them (staff)“ 

� “I like to do as much for myself as I can, I cook 

my own tea and sometimes do it with other 

learners” 



CQC reports - outcome 4 

What concerned CQC: 

� We found care plans did not give staff a concise and 

collective direction on how to best support people 










(outcome 4) 

� Met this standard 



Assessing and monitoring the quality of service � Met this standard 


� The plan did not say how staff would recognise if the 

illness was deteriorating or what they should do about 

this (diabetes) 

� Goals had been set for one person but it was difficult to 

evaluate progress made as records were not up to date 

� There were no health action plans and care plans were 

not routinely devised using person centred principles 












(outcome 4) 






CQC reports – methods used 

Methods used: 

�we spoke to learners and staff and 

observed interactions between them 

�Through a process called pathway 

tracking we followed the care of two 

learners 

�Talked to staff and visitors 




What CQC liked: 


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(outcome 4) 




� Equality and diversity had been considered and dietary, 

religious and cultural needs were recorded and said 

whether the person preferred personal care from 

someone of the same gender 

� Care plans recorded preferences and wishes, support 

needs, preferred routines and risks were identified as 

well as action to reduce known risks 



� People were empowered to make choices and informed 

decisions about the care treatment and support they 

received 




What CQC liked: 










(outcome 4) 






� A newly appointed member of staff said they 

had a comprehensive induction programme 

which included safeguarding 

� 2 staff were able to describe what action they 

would take in the event of abuse being seen, 

disclosed or suspected 

� People said they would talk to staff if they had 

any concerns or worries. They were confident 

that staff would listen to them and act upon any 


issues they might have 











(outcome 4) 






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What concerned CQC: 

� Although the majority of staff had received training 

we found that they had limited knowledge about the 

procedures for protecting people 

� There is no specific reference in the policy to when a 

referral is to be made to the local authority adult 

protection team. 

� There had been no formalised process for learning from 

safeguarding events to prevent similar recurrences 



Preparing for inspection: 

Within your service: 

� Make sure people who use your service and your staff 

know what will happen during inspection 

� Identify contact arrangements so that someone senior 

can attend quickly when an inspection happens 

� Make sure key records and policies are kept up to date 

and your staff know how to access them 




After the inspection: 

� Regularly check emails for arrival of the report 

� Respond to CQC on factual accuracy within 10 working 

days 

� If action plan needed, make sure it is SMART 










(outcome 4) 

� Tell CQC when action completed so that website can be 

changed to show you are compliant 









Ensure CQC has accurate information: 

� Submit notifications on time and ensure they contain 

clear information about the event and what you have 

done 

� Encourage people to use the Please tell us your 

experience part of CQC’s website 




On the day: 

� Check their ID! 

� Offer a quiet space for discussion and feedback 

� Identify person to offer support if needed 

� Before they leave, check they have everything they need 



Important CQC documents to be aware of: 

A suite of documents (including guidance for inspectors) on Equality 

and Diversity: 

http://www.cqc.org.uk/information-our-staff/equality-and-human-rightsguidance-our-inspectors 

Observation prompts: 

http://www.cqc.org.uk/search/apachesolr_search/observation%20prompts 

Preparing for CQC Inspections: 

http://www.cqc.org.uk/sites/default/files/media/documents/cqc_preparing_for 

_inspection_-_cpa_version_-_final.pdf 

Whistle blowing guidance for providers and for workers: 

http://www.cqc.org.uk/contact-us (then click on Whistle blowing tab) 



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The future for CQC? 

We therefore conclude that, although regulation is being 

delivered more cheaply, the Commission has not so far 

achieved value for money in regulating the quality and 

safety of health and adult social care. National Audit 

Office - Dec 2011 

David Behan to be new Chief Executive at CQC from 

current role as Director General for Social Care, Local 

Government and Care Partnerships at the Department of 

Health, prior to which he was Chief Inspector of the 

Commission Copyright: Deborah Sterry for Social Social Care Care Regulation Inspection 

Consultant and 


I hope you have found this presentation helpful. 

Deborah Sterry 

Social Care Regulation Consultant 

Tel: 07548 280032 

deb.sterry@hotmail.co.uk 



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Preparing for CQC inspection Deborah Sterry

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