David Finney gives the latest essential chapter on preparing for Care Quality Commission inspection
Do you know what’s happening with CQC inspections? You may have had a CQC inspection already, or you may be waiting for the next email or visit. Well, from now on all inspections will be announced approximately 20 weeks in advance, giving you an opportunity to send all the information to CQC in a ‘Provider Information Return’ in advance of the visit.
You are probably aware that inspections have switched within CQC to the Hospitals Directorate. This means that the focus of inspection is now firmly on the quality of the treatment on offer rather than the social care matters, which predominated previously. You will probably also find that, alongside the allocated inspector, there may be a ‘specialist professional advisor’ with a clinical background.
Some services have had a positive experience of inspection while others have found it negative. To my knowledge, four rehabs have already closed following their inspection, realising that they were not going to meet the standards required. Others have had to work hard to achieve compliance.
So how can you prepare for your inspection?
- Detox services:
The emphasis during inspection will be on the clinical and prescribing aspects of the service and CQC’s expectations are that there will be:
- Medical oversight by:
- A consultant psychiatrist with specific addiction treatment knowledge or
- A GP with at least RCGP part 1 in the treatment of alcohol and drug misuse.
- Nursing staff with the right training.
- Adherence to NICE guidelines on alcohol and drug misuse.
- Clinical assessment tools.
- Thorough physical health assessments on all people joining the service.
- A multi-disciplinary team (MDT) which coordinates treatment.
- A clinical governance framework which includes audits, a track record on safety and quality assurance.
- Mental Capacity Act and the Deprivation of Liberties Safeguards (DOLS)
CQC have a statutory duty to monitor the implementation of this Act. Obvious examples of where this Act applies are when a person is intoxicated and so has no capacity to make a sensible decision, or when they have alcohol-related brain injury which limits their cognitive functioning. So:
- Staff need to be trained and be able to explain the principles behind the legislation.
- Staff need to be able to explain that any restrictions in the treatment programme are not infringements of people’s liberty, but agreements which people make to ensure effective treatment.
It is important to highlight the fact that CQC have become much more robust in their enforcement procedures. This means that where services are found to be non-compliant:
- CQC may initially seek the voluntary agreement of the provider to cease admitting people to the service until certain measures are in place.
- In some cases CQC may quickly issue statutory warning notices if they believe that concerns about practice are serious.
- Other crucial areas
- Risk assessments and risk management plans need to be clearly outlined. Recently CQC have specifically been asking about risks associated with early discharge, suicide or self-harm and destabilisation following detoxification.
- Documentation must be thorough. There must be an audit trail of decision making and care planning. Also CQC may ask for a whole range of policies and procedures be sent to them.
- What do you need to do?
Ensure all staff are inducted into the meaning of the CQC regulations and the five key questions.
Undertake a thorough audit of the operation of your services before your inspection. If you are not sure what to do, then seek advice from an external advisor/trainer who can explain exactly how to achieve compliance.
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