Preparing for a CQC Inspection: PART SEVEN
Accessible Information Standard
In regards to meeting the Accessible Information Standard, CQC will check if your service is compliant. This standard has been a legal obligation since August 2016 for all NHS care providers and publicly funded adult social care organisations. The Standard outlines a consistent approach to identifying, recording, flagging, sharing, and meeting the information and communication needs of patients, supported individuals, carers, and parents with a disability, impairment, or sensory loss.
To ensure compliance, it's important to include the information and communication needs of people and their carers in your assessment and care plan templates. Keep records of instances where you have provided support or arranged accommodations for people with specific communication needs, such as signers, large print documents, or braille readers. CQC has also published guidance on how to meet the Accessible Information Standard.
When inspected by CQC, you need to show evidence that you actively support people in developing their care plans, whether they are on paper or in electronic files. CQC will want to ensure that the individuals you support have actively agreed on the outcomes or targets they would like to achieve and that there is a plan in place to support those goals.
NICE website provides helpful information on care planning for people supported by services and for providers. Care plans should include outcomes that are set by the person receiving support, such as increasing mobility in the home, and should have specific examples of what those outcomes would look like, such as standing up safely from a sitting position. Care plans must be reviewed annually, but more frequent reviews may be necessary as needs, outcomes, and preferences of the individual change.
To ensure the safety and quality of care, CQC requires complex care providers to have a clinical governance system in place, which involves monitoring and improving health and safety. Providers must have appropriate policies and procedures that are regularly reviewed.
Complex care covers a range of services such as tracheostomy, suction, and dressings, which may involve delegated healthcare tasks. Skills for Care offers guidance on managing situations where care workers may carry out delegated healthcare interventions under the supervision of a regulated healthcare professional. The guide outlines roles and responsibilities, but each intervention should be assessed individually with a person-centered approach. You can access the Delegated Healthcare Tasks guidance on the Skills for Care website.
Compliments & Complaints
CQC will assess your complaints policy and procedures and expect to see evidence of monitoring and analysis of complaints over time, including identification of trends and potential areas of risk requiring attention. It is important to differentiate between one-off incidents and recurring trends that highlight systemic breakdowns in the care process.
Providers should be prepared to give substantiating evidence, particularly for serious notifiable events specified in Regulation 18 of the Registration Regulations. CQC will also evaluate the improvements made to the service in response to complaints. Keeping records of complaints, positive feedback, and compliments from clients, staff, and other stakeholders is essential. Outstanding services can demonstrate how they collect and evidence feedback from these groups. In addition to written compliments, verbal compliments received by staff should be documented and included in the records.
GDPR & Data Protection
CQC is not responsible for evaluating compliance with the General Data Protection Regulation (GDPR); however, you must be able to demonstrate that you have knowledge of data protection and the GDPR principles. As a data controller, it is your legal responsibility to inform the people you serve, your employees, and other individuals whose personal information you possess that their data may be shared with third parties.
CQC has the authority to access records, including personal and medical records, personnel files, and other confidential information held by your service. If a person expresses their unwillingness to allow CQC access to their personal information, the Commission will try to respect their request to the greatest extent feasible. Nonetheless, CQC may access the records if deemed necessary to perform an inspection effectively.
It is vital to keep your policy updated and make sure that staff members understand their responsibility to keep the personal information of the individuals they support confidential and secure. The Data Protection Act 2018 (DPA 2018) domesticates the GDPR and also encompasses other areas unique to the UK.
Equality & Human Rights
CQC places a strong emphasis on equality and human rights. Services rated as Outstanding have shown to use these approaches in their development and focus on equality for staff and the people they support.
For homecare services, equality means ensuring dignity, security, autonomy, choice, support for decision-making, privacy, and enabling social and civic participation. An equality and human rights approach provides an ethical framework for decision-making that is person-centred and ensures that rights are only restricted where proportionate and necessary. It also provides guidance on how to balance competing rights and duties in situations of conflict.
CQC also assesses how well providers ensure person-centred care for people with protected characteristics, which are defined in the Equality Act 2010. CQC publishes equality objectives to meet these regulations for a four-year period, currently 2021-2025.
CQC has issued guidance on Human Rights approach in social care services.
Duty of Candour
The intention of the duty of candour legislation is to ensure that providers are open and transparent with people who use services. It sets out some specific requirements 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. CQC have issued guidance for care providers which will help you ensure your service is complaint at the time of inspection.
The COVID-19 pandemic has emphasised the importance of effective infection prevention and control (IPC) measures in homecare to protect staff and the people they support. CQC has carried out IPC inspections to assess how services were managing risks associated with COVID-19 and will likely continue to ask about how your service is managing COVID-19 risks as part of your overall IPC measures.
Providers should practice and assess IPC measures as part of their ongoing activities. The government has published general guidance on infection prevention and control in adult social care. Conducting infection control audits will provide evidence to the regulator about how IPC is managed within your organisation. The audit could include risk assessments for the prevention and control of infection, any outbreaks of infection that have occurred, IPC audits undertaken, actions taken following outbreaks of infection, training carried out by relevant staff, and reviews and updates of policies and procedures.
When assessing the effectiveness of care, CQC takes into account whether care providers comply with legislation, standards, and evidence-based guidance, including NICE Guidelines. Although NICE Guidelines are not legally required, they are widely considered to be the "Gold Standard," and care providers who choose not to follow them must demonstrate an evidence-based alternative.
To support care providers, NICE has compiled all its resources relevant to Adult Social Care. NICE has mapped its quality standards and managing medicines recommendations against CQC's Key Lines of Enquiry in a Quality Improvement Resource. While this resource is not a formal CQC requirement, care providers may find it a useful tool for quality assurance and auditing within their services.
It's important to have up-to-date Safeguarding policies and procedures in place, which are regularly audited, to demonstrate compliance to CQC. Here are some tips to make sure you comply with safeguarding during your inspection:
- Involve people who need care and support in discussions about their safety. Understand their needs and preferences and include this information in their care plans
- Foster a culture of openness where staff feel comfortable reporting any allegations of abuse or neglect, which will be fully investigated to ensure people are protected
- Investigate safeguarding incidents transparently and collectively review incidents to identify trends
- Keep detailed records of safeguarding incidents, including how they were handled, involvement of other agencies, and any follow-up actions or learning. Key records may include risk assessments, care plans, observations, financial transactions, complaints, medication, rosters and logs, and training and supervision notes
- Ensure staff and people who need care and support know how to report poor practice without fear of retaliation
- Stay in regular contact with the local safeguarding team
- Share your knowledge and experience of adult safeguarding with local groups, networks or member organisations
- Provide information about safeguarding through various channels such as displaying a safeguarding adults policy, a whistle-blowing policy, and including information about safeguarding in marketing materials, website, and customer welcome pack
Feedback about your Service
Experience of Care
During inspections and assessments, CQC places a strong emphasis on the quality and safety of services based on what matters most to people. This means that CQC will talk to the people you support to gain their feedback on whether they are treated with compassion, dignity, and respect, and if their choices are respected.
Additionally, CQC will increasingly focus on the experiences of not just the people you support, but also their families and other stakeholders who may wish to express their views. This feedback will be included in the new scoring system, which may impact the rating of your service.
Regularly surveying clients and their families or carers is an important part of quality assurance processes. It will provide you with evidence of how well your service is doing and what could be improved.
Download our Client Survey Template here.
If you have any questions about CQC inspections join us in Care Begins at Home, a group created to provide free knowledge and information to care providers and family carers.