- The CQC inspection report will be published on the CQC website.
- CQC has enforcement powers available to it if concerns are identified that are linked to a breach of a regulation.
- Inspectors will assess the service against CQC’s five key questions, asking if the service is safe, effective, caring, responsive and well-led.
- Inspections will be led by a specially trained dental inspector who may be accompanied by a specialist dental adviser.
- There are two types of inspection: comprehensive and focused.
At present, the Care Quality Commission (CQC) inspects approximately 10% of providers of primary care dental services.
Unlike the other sectors it regulates, CQC does not presently give ratings to primary dental care services. However, the CQC’s inspection report will be published on the CQC’s website, and CQC has enforcement powers available to it if concerns are identified that are linked to a breach of a regulation. It is therefore important that you are well prepared for an inspection and know what to expect from it in order to ensure the best outcome for your service.
This article will set out what you can expect as well as some tips for ensuring the inspection runs smoothly.
Inspections will assess the service against the CQC’s five key questions, asking whether it is:
- responsive to people’s needs
Inspections will be led by a specially trained dental inspector who may be accompanied by a specialist dental adviser.
There are two types of inspections: comprehensive and focused.
Comprehensive inspections are usually announced two weeks before the inspection. They will address all five of the key questions set out above. Comprehensive inspections will generally last one day at the practice and the inspection team is likely to include a specialist dental adviser.
Focused inspections are carried out as a follow-up to a previous inspection, or in response to a particular concern. As such, they may be unannounced. Focused inspections will not address all five of the key questions. The composition of the inspection team will depend on the concern being followed up. A focused inspection may be carried out in conjunction with one of CQC’s partners, for example NHS England.
Before an announced inspection
More than two weeks before the inspection:
- The regional inspection teams will liaise with your NHS area team to gather information about the practices in your area, for example any complaints received, assessments undertaken or investigations carried out.
- CQC will ask your local Healthwatch for any information it has about the quality of care provided by the practices in your area, including evidence of good-quality care and any concerns.
Two weeks before the inspection:
- The CQC inspector will call you to introduce themselves and talk through what will happen on the day of the inspection in more detail so you can prepare. Your preparation should include refreshing yourself on the content of the CQC publication Provider handbook for primary care dental services.
- You will receive a letter from CQC to confirm the date of your inspection and to request a copy of your statement of purpose, information on complaints/compliments and staff details. You will normally be given a deadline to respond to CQC’s request for information and you should ensure that you provide the requested information in good time.
- CQC will send you comment cards for your patients to complete and posters to advertise the inspection, telling patients how to share their experience of your service with CQC. You should ensure that patients are encouraged to provide feedback about your service.
On the day of the inspection:
- At the start of the visit, the inspector will meet with the registered manager for a short introductory session to explain how the inspection will be conducted. You should ensure that you set aside some time for this and use the opportunity to tell the inspection team the things you feel that you do well at the service.
- The inspection will combine interviews with staff and patients, collecting and reviewing the comments cards that people have completed and reviewing various pieces of documentation within the practice. The documentation reviewed could include:
− equipment maintenance certificates
− your radiation protection file
− audits and action plans
− policies and procedures in relation to infection control
− policies and procedures in relation to staff recruitment
− staff training records
− patient satisfaction surveys and findings.
- You should ensure that documentation is up to date and accessible to the inspectors to allow you to easily demonstrate how your service is safe, effective, caring, responsive and well-led.
- At the end of the inspection:
- The inspector will provide feedback to the registered manager (or most senior person in charge as agreed at the outset of the inspection). This will be high-level initial feedback only; however, it is important that you keep a record of it as it may be relevant should you need to challenge any of the findings during the factual accuracy stage. Accordingly, you should take good notes of the feedback session or even consider bringing a colleague to the feedback session as a note-taker.
- The inspector should cover their findings to date, although these will not be their final conclusions as they will carry out a further analysis of all the evidence following the inspection.
- If there are any matters with which you do not agree, you should raise them with the inspectors at the time and follow this up with supporting evidence, where relevant, as soon as possible.
- The inspector should outline any issues that were escalated or require immediate action and outline any plans for follow-up or additional visits (unless these are to be unannounced). If enforcement action is being considered you should consider seeking legal advice as soon as possible.
- The inspector should outline the next steps, including factual accuracy checking of the draft report (see below) and answer any questions from the practice.
After the inspection – the report and factual accuracy comments
After the inspection, CQC will produce a draft report which will be structured to reflect the five key questions set out above. It should also include information about notable practice and will set out any evidence about breaches of the regulations.
The draft report will be sent to you so that you can provide your factual accuracy comments. This is your one chance to challenge inaccuracies within the report; therefore, it is important that you respond to CQC within the deadline specified (usually 10 working days). Provide your comments and further evidence in relation to any matters that you consider to be inaccurate. When framing your comments, you should bear in mind that CQC ought to act proportionately, follow its own guidance and report accurately. This would include providing evidence to support its statements and conclusions.
If you do have concerns with your draft report then you may wish to seek legal advice and assistance with the factual accuracy process. In these circumstances you should bear in mind the deadline set and ensure you seek advice promptly to ensure a timely response to CQC.
Once the factual accuracy process is complete and any changes have been made to the draft report it will be published on the CQC website.
Further information about CQC inspections can be found at: www.cqc.org.uk/dentalproviders.
Use the following item in the Toolkit to put the ideas in the article into practice:
About the author
Laura Paton is a solicitor for Ridouts LLP, a law firm specialising in health and social care law. Laura joined Ridouts from the Fitness to Practise department of the General Dental Council where she gained a wealth of experience in professional disciplinary cases. www.ridout-law.com