- 5 Key Lines of Enquiry will be used to test practice success.
- Both Comprehensive and Focused inspections will be conducted.
- Sourced information will be collected to back up future inspections.
- Intelligence monitoring systems will continue to observe Dental practices.
In developing the methodology to the new approach of inspecting dental practices, the CQC (Care Quality Commission) has taken into consideration the feedback from its public consultation, the pilot inspections, engagement with providers and other local and national stakeholders in 2014. As a result, the new inspection guidelines published in March 2015 by CQC aim to include specialist inspection teams led by an inspector with clinical and non-clinical experts who have direct experience of working with the dental services.
How CQC regulates primary care dental services
The new handbook describes its approach to regulating and inspecting primary care dental services. Its inspectors use professional judgement, supported by objective measures and evidence, to assess services against our five key lines of enquiries (KLOEs):
- Are they safe?
- Are they effective?
- Are they caring?
- Are they responsive to people’s needs?
- Are they well-led?.
Its aim is to inspect 10% of providers based on a model of risk and random inspection, as well as inspecting response to concerns about whistleblowing, complaints, enforcement activity, concerns from the General Dental Council and NHS England. The five KLOEs will help regulate dental practices and these in turn will help to find any breaches in the regulations and the fundamental standards. The five areas are defined as:
- Safe - people are protected from abuse and avoidable harm.
- Effective - people’s care, treatment and support achieves good outcomes, promotes a good quality of life and is based on the best available evidence.
- Caring - staff involve patients, treating them with compassion, kindness, dignity and respect.
- Responsive- services are organised so that they meet people’s needs.
- Well-led - the leadership, management and governance of the organisation assures the delivery of high-quality and person-centred care, supports learning and innovation, and promotes an open and fair culture.
Two types of inspections
There will be two different types of inspections: Comprehensive and Focused.
1. Comprehensive inspections
Comprehensive inspections will be:
- carried out at 10% of registered practices in 2015/16
- address all five key questions CQC asks of services
- involve one day at the practice
- most likely include a specialist adviser
- will usually be announced two weeks before the inspection.
2. Focused inspections
Focused inspections will:
- follow-up to a previous inspection or respond to a particular issue or concern
- will not address all five key questions CQC asks of services
- team composition and size will depend on the concern(s)
- may be conducted in partnership with one of our partners (for example, NHS England)
- may be unannounced.
Will I be inspected?
Practices will be selected based on which are seen as being at greater risk of not meeting the fundamental standards. The indicators include the following:
- providers registered for more than 18 months, that have not yet been inspected
- concerns or risks identified in previous inspections or from information gathered.
Concerns or complaints received about a provider related to the fundamental standards; when there is a safeguarding alert or when a member of staff (including whistleblowers) contacts the CQC with concerns relating to a possible breach of the fundamental standards.
CQC will make judgments from gathering information available to them from three main sources:
- The ongoing relationship with the dental practice.
- Information gathered in the weeks before the inspection to help plan the inspection.
- The inspection visit itself.
Information from the ongoing relationship with the dental practice
Information from the ongoing relationship with the dental practice will include continuous monitoring of local data and intelligence and risk assessment. Information collected will include the number and types of complaints and compliments that people make about their care and how these are handled. The results of the “Friends and Family Test” will also be included especially for corporate providers.
Planning of the inspection
The information gathered prior to your inspection will determine what the inspection entails, who is spoken to and what is looked at during the visit. Data from sources such as people who use services, will be a key principle of the approach to inspecting. Inspectors will seek out and listen to the experiences of the public, people who use services and those close to them, including the views of people who are in vulnerable circumstances or who are less likely to be heard. Other sources of information will include NHS Area Teams, local Health watch organisations/scrutiny committees etc. Information will also be sourced from what the actual providers supply to the CQC prior to the inspection. Practices will have five working days to respond to their request. The information requested is likely to include:
- Quality monitoring information, such as information about compliments and complaints.
- Information about staff employed.
- An up-to-date statement of purpose.
- Information about membership of any accreditation/good practice scheme.
Information from the inspection
At the start of the practice visit, the inspector will meet with the registered manager. This will explain:
- how CQC regulates primary care dental practices
- who the inspection team is
- the scope and purpose of the inspection, including relevant powers and the plan for the day
- how concerns identified during the inspection will be dealt with
- how findings will be communicated.
The practice will be asked to share any concerns it has identified itself in its ability to meet the requirements of the regulations (including the new fundamental standards) and what it is doing about it. Any notable (best practice) things done will also be asked.
The on-site inspection
The on-site inspection will entail some of the following:
- observations of care
- what people, carers and staff tell them
- care environment and facilities
- records and document reviews including treatment plans, medical histories etc.
- gathering the views of people who use services by:
- speaking with people
- using comment cards placed in reception areas to gather feedback from people who use services, their family and carers
- using posters to advertise the inspection and provide an opportunity to speak to the inspector or any other members of the inspection team - these will be put in areas where people will see them
- exploring options for using digital routes for people of all ages to share their experience, through text messaging, social media, and through mobile apps
- using the information gathered from their work looking at complaints and concerns from people who use services
- gathering the views of staff, including:
- dental nurses
- individual dentists
- practice managers
- reception staff
- current and former whistleblowers
Other inspection methods and information gathering:
- reviewing parts of the dental records
- reviewing operational policies and supporting documents
- observing processes such as decontamination
- looking at the premises and facilities.
If the inspection is being carried out by a team, the lead inspector will review the emerging findings with the team throughout the day. This keeps the team up-to-date with all issues and enables them to shift the focus of the inspection if they identify new areas of concern. It also enables the team to identify any further evidence or facts that might still be needed.
Feedback on the visit
At the end of the visit, the inspector will provide feedback to the registered manager or most senior person in charge. The initial feedback will cover things like:
- Explaining the findings to date, but noting that further analysis of the evidence will be needed before final judgments can be reached on all the issues.
- Any issues that were escalated during the visit or that require immediate action.
- Any plans for follow-up or additional visits (unless they are unannounced).
- Explaining how they will make judgments.
- Whether they need additional evidence or are likely to seek further specialist advice.
- Explaining the next steps, including factual accuracy checking of the draft report, final report sign-off and publication.
- Answering any questions from the practice.
Publication of the results
CQC will publish the inspection reports on its website at the end of the inspection. Any types of action and enforcements will be given to the practice including breaches in the fundamental standards. Appropriate action and follow up will be conducted by the CQC.
- Guidance for providers on meeting the regulations, CQC, March 2015:
- How CQC regulates: Primary care dental Services, Provider handbook, CQC, March 2015
Use the item below to put the ideas in this article into practice:
About the author
Dr Shilla Talati BDS graduated from Guys Hospital in 1999 and has been in general/private practice ever since. She was a partner MD of Dental Perfection in Coventry for several years where she had a special interest in the management side of her dental practice. She has run several courses for the GDP in general practice and is now involved in practice management issues including staff training, compliance monitoring, and staff motivation.