CQC monitor, inspect and regulate services in England to make sure they meet fundamental standards of quality and safety and they publish their findings to help patients choose their care. Inspections are an integral part of this, and something dental providers have become accustomed to.
In April 2015, CQC redefined its approach to inspections. You can find information on how inspections are now structured and what inspectors look for in CQC's provider handbook for dental practices.
The inspection process
The role of CQC is to make sure health and social care services provide people with safe, effective, caring, responsive and well-led care, which form the five Key Lines of Enquiry (KLOEs) for inspectors.
The five Key Lines of Enquiry:
- 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 and treat people 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 care, supports learning and innovation, and promotes an open and fair culture.
The focus on the KLOEs will help CQC make a consistent judgement. The provider handbook includes some examples of ways to demonstrate how you are meeting the regulations. They are not meant to be an exhaustive list or a 'checklist' and all providers are reminded to refer to the Guidance for providers on meeting the regulations.
To date CQC have found that the dental sector poses a lower risk to patient safety than other sectors they regulate.
The current plan is to inspect only 10% of dental services (approximately 1,000 providers) each year. The reasoning for this is that, to date CQC have found that the dental sector poses a lower risk to patient safety than other sectors they regulate. Practices will be selected for inspection at random or on the basis of previously identified risk.
Unlike other sectors that CQC regulates, primary care dental services assessed in 2015/16 under the new approach will not be given a rating, although CQC reserve the option to do so in the future. They believe it would be unfair and a disadvantage to other providers to rate only the 10% of providers they inspect.
Dental sector inspection teams will comprise specially trained dental inspectors supported by specialist advisers with a dental background, who may attend inspections or provide advice remotely.
Types of inspection
There are two types of inspection:
- Addresses all five key lines of enquiry.
- Usually takes one day at the practice.
- Likely to include a specialist adviser.
- Usually announced two weeks before the inspection.
- Follow-up to a previous inspection, or to respond to a particular issue or concern.
- Will not address all five key lines of enquiry.
- Team composition and size will depend on the concern(s).
- May be conducted in partnership with one of CQC's partners (for example, NHS England).
- May be unannounced.
To help providers prepare for inspections, CQC have produced a quick guide entitled What to expect when we inspect.
They have also written a series of Mythbusters and tips for dentists. Although designed to support inspectors as they assess the quality of primary care dental services, providers may find them helpful and reassuring.
CQC have worked closely with stakeholders over the last year in developing a clearer and fairer assessment process for the dental sector. They are currently looking at ways of celebrating excellent practice and this is something we should start to see included in reports in the future.
We would encourage members to keep up to date with CQC developments, and if you have any queries relating to your own practice, please contact our advice line on 0800 374 626 or email us email@example.com for further advice and guidance.
New fundamental standards
Since September 2014, I have been attending regular meetings with CQC as part of their Dental Reference Group, set up to enable key stakeholders to comment and feed back to CQC as they embarked on the process of developing the new approach to primary dental care services inspections.
CQC's previous approach to inspections was to assess whether or not a provider was meeting the Health and Social Care Act 2008 (Regulated Activities) Regulations 2010.
From April 2015, these regulations were replaced by the new Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, which include the following important additions or amendments, which every provider needs to be aware of.
- Regulation 5: Fit and Proper Persons: directors
CQC have explained that the introduction of a statutory fit and proper persons requirement for directors is an important step towards ensuring an open, honest and transparent culture where those in control can be held to account. The intention of this regulation is to ensure that people who have director-level responsibility for the quality and safety of care, and for meeting the fundamental standards, are fit and proper to carry out this important role and to ensure their accountability. At the point of registration, the provider will sign to say the directors meet the requirements. Inspections will assess that due diligence has been followed in the recruitment and performance management of directors under the well-led question and this will be reported on.
- Regulation 20: Duty of Candour
The introduction of a duty of candour is a direct response to the Francis Report on the Mid Staffordshire NHS Foundation Trust which recommended that a statutory duty of candour be introduced for health and care providers. This has now been enacted in law (see Rupert Hoppenbrouwers' article).
In interpreting this regulation, the definitions of openness, transparency and candour used by Robert Francis in his report have been adopted:
- Openness – enabling concerns and complaints to be raised freely without fear and questions asked to be answered.
- Transparency – allowing information about the truth about performance and outcomes to be shared with staff, patients, the public and regulators.
- Candour – any patient harmed by the provision of a healthcare service is informed of the fact and an appropriate remedy offered, regardless of whether a complaint has been made or a question asked about it.
The intention of this regulation is to ensure that providers are open and transparent with people who use their services. It also sets out specific requirements that providers must follow when things go wrong with care and treatment, including informing people about the incident, providing reasonable support, providing truthful information and an apology when things go wrong. This is of course advice the DDU has given to our members for many years.
CQC have published guidance to help dental providers understand how they can meet the new regulations.