Peter Killwick from Verita looks at how independent healthcare providers can respond to an adverse CQC inspection and what they can do to improve patient safety and quality.
The work of the CQC is crucial in both maintaining and improving patient safety and identifying areas where performance is falling short of requirements. Our recent work with providers suggests that the CQC is developing a much closer focus on organisational leadership and the impact – positive or negative – that this can have on performance. The well-led domain is now key. Executives of all healthcare providers are well advised to recognise and prepare for this.
An understandable apprehension around an inspection can become a real threat to the business if the report reaches adverse conclusions resulting in enforcement notices. Day to day operations can be disrupted, staff morale impacted, insurance premiums hugely increased, and, in the worst case, entire services shut down. So – how best to respond if an inspection goes badly?
Our primary advice is to genuinely examine the findings and to resist the instinctive reaction to contest the report, unless you are certain that the inspector is in error. Remember that by the time the CQC reports, it may be very difficult to change their opinions – time spent challenging the detail of the findings may be better spent elsewhere. If there is substance to their concerns, it is vital to act fast and to commit to fix the problems. After all, most findings by inspectors aim to identify patient safety concerns, and it is in your interest to know why the inspector considers safety may be at risk.
A factually accurate report is in everyone’s interest, and it will allow you to focus with confidence on the right issues. In your initial conversations with the inspector, it is essential to provide immediate confidence that you acknowledge the issues and have the organisational capacity and the will to fix them.
Understanding the root causes of the problems is essential. It is possible that independent diagnosis may help you see a clearer picture, as there may well be a gap between what you think is being done (your policies, protocols and procedures), and what is really being done on the front lines. To understand this, it is essential to take a “deep slice” approach from board-to-ward. This will help you to avoid complacency and should ensure that confirmation bias does not block an effective diagnosis.
Again, it is possible that the most effective way to do this may be with outside help, not only to provide extra bandwidth for the task, but also because an experienced partner will have proven diagnostic tools at their disposal and direct knowledge of how other healthcare organisations are structured and run.
Once reliable evidence of the problems and their causes has been gathered, a realistic plan for the remedial actions must be developed and, crucially, shared with the inspectors. This will give them confidence that their findings have been understood and addressed and that there is a coherent path to implementation. Providers should guard against the temptation to be over-optimistic in the time that it will take to reach the goals. Inspectors are generally very experienced and will not see as credible ‘root and branch’ reforms (if these are required) that are scheduled to be completed in short timeframes. In our experience, it sends a much stronger message to commit to (and execute) any actions mandated within the enforcement notice timeframe, and to adopt a more measured approach to wider reform.
It is important to factor in not just the necessary changes to organisation, governance, systems, processes and practices, but also the need to support your people through communication, training, development and clear leadership. Stakeholders must be informed of and aligned with the plans, and internal and external communication must be managed proactively to maintain commissioner and patient confidence in your services.
Our clients have found that continual engagement with the CQC team is the best way to provide them with confidence in the progress being made. If this is to be optimal, a detailed plan of actions taken and their impact on service delivery is key. This can demonstrate that interventions are more than just a paper exercise and are being established throughout the organisation. We know that providers are committed to improving performance and patient safety and the response to an adverse inspection gives you the opportunity to demonstrate that commitment, not just to the CQC, but to all your stakeholders.
There is no question that there will be a cost – potentially significant – in getting the response right, but a much bigger cost to getting it wrong.
Obviously, it would be preferable to not fall foul of the regulator in the first place, so in a future blog we will outline the potential problem areas that can be proactively assessed to ensure this.