All change for CQC – By CQC Chris

Source: Practice Index – By CQC Chris 13.4.23

There’s more change coming and it’s not necessarily all good! Here’s an overview of what’s potentially going to happen this year.

More than a quarter of inspectors are being changed to ‘assessors’ in early 2023. These new, purely home-based, regulatory spies will be responsible for carrying out assessments without announcement, which could change ratings without any CQC employee visiting services. If that doesn’t give you pause for thought, consider what the CQC would find if they carried out the Ardens searches of your patient list right now, along with your QOF data. Then imagine your rating changing tomorrow without even preparing coffee and expensive biscuits for your CQC inspector visit. This is all a real possibility under this year’s proposed CQC changes.

The CQC want to enable fluid changes to ratings using remote assessments and to only carry out site visits where they are “vital”. This means that data will play a HUGE role in the future in deciding how services are rated and inspected. It will also make ratings much more changeable.

Currently, the CQC use a variety of NHS England QOF data such as childhood immunisations and cervical screening rates to consider how services are performing. This data is taken from specific dates in the past (sometimes over six months ago!), which means that if your service was underperforming six months ago, that is how the CQC will view your practice at the time of the inspection. Furthermore, an inspector usually visits your practice and considers your mitigation, explanation, and circumstances. But the 2023 plans aim to enable the CQC to use current QOF and EMIS data from entire patient lists at the time of assessment. This means that if you have 100 patients coded as not having had safe monitoring, the CQC will be able to use this data immediately to alter your rating with no actual practice visit from an inspector.

From a regulatory perspective, this is highly efficient, and it also ensures consistency across all assessments. Yet it will mean that services face significant, constant pressure to ensure their patient lists and data are meeting targets and guidelines. Furthermore, services will have to ensure that clinicians and staff pay impeccable attention to detail when coding, summarising, and recording information in electronic records systems. The Ardens searches have caused significant mayhem since their inception in CQC inspections in 2022.

What will these searches result in if they are used constantly across all practices at any given time without warning?

Many practices have used the factual accuracy process to challenge findings or conclusions reached by the CQC without proper consideration of additional computer systems, records, test results or faulty coding. This new assessment process, in its current proposed form, won’t give services the option to challenge a new rating or conclusion based purely on data. A rating will potentially be placed on a service without any of the previous warning, investigation or analysis.

Of course, the CQC view this as a black-and-white issue that enables direct and specific regulation across the country using the same yardstick. But all practice managers recognise the vast grey area of faulty coding, unscanned/coded test results or secondary care letters and, of course, the patient-by-patient bespoke care that GPs provide daily.

Another perspective of this approach is that the CQC and the public will finally be able to see the real pressure and workload faced by GPs in England. As voted at the English LMC last year, perhaps all services should be rated ‘Requires improvement’ to honestly reflect the crisis primary care services are in. This new approach certainly could result in ratings dropping across the country, or perhaps the thresholds for ratings would have to be adapted. In 2022, the CQC ran a sampling project of services rated ‘Good’ within the last five years, which found, sources have informed us, that the majority were not in fact ‘Good’ at all. This could reflect the current crisis and the resultant changes in services, or it could be a demonstration that the CQC’s new goalposts are simply too high.

Does primary care need a brutal regulatory assessment of reality to enable reform and demand attention? Or will this new approach just enable the CQC to regulate more services into the ground?

Either way, change is coming by the end of this year. Click here for the source.