By Dr Pallavi Bradshaw, Senior medico-legal adviser at Medical Protection
Dr Pallavi Bradshaw
The Care Quality Commission’s (CQC) strategy, published last year, aims to deliver a more targeted, responsive and collaborative approach to regulation, so that more people get high-quality care.
The CQC intends to become more intelligence-driven by strengthening the way it uses data and information to underpin its decision-making and identify risks of poor care, which we welcome in principle.
In particular, the CQC has said it wants to bring together information from its inspections, service users and data from its partners to better equip it to monitor changes in quality. What this might mean in practice is where our concerns lie.
Over the course of the past year, we have raised concerns in a number of consultations that together have informed the CQC strategy.
One worry is that the CQC requesting information from the GMC prior to inspections could be prejudicial to the inspection and may not even be relevant.
This is particularly true if a doctor is subject to a complaint at the time of the CQC request to the GMC – a complaint which is subsequently found to be without foundation, but only after the CQC has concluded its inspection.
The CQC should carefully focus on how it can avoid prejudicing its inspections when gathering information from other sources and we will continue to monitor this closely on behalf of our members.
Clearly, patient feedback is a key tool for doctors in assessing and improving their practice.
However, we would be concerned if the CQC were to find itself in a place where it relied too heavily on patient feedback about services on social media sites such as Twitter and Facebook.
Comments provided online may not be accurate or fair, and they need to be utilised with this in mind.
An inspection’s outcome can be detrimental to a practice’s reputation – which is why it is imperative that any information collected is robust, analysed and interpreted accurately. Care must also be taken to ensure a balance is achieved between the use of quantitative and qualitative data and information.
Frequency of inspections
From our experience with doctors, we know CQC inspections can be disruptive and time-consuming. From the first notice of an inspection, through to gathering preparatory materials and evidence and the often lengthy wait for the report, it can be an extremely disruptive process for the doctor and the wider team too.
The strategy has recognised concerns with the frequency of re-inspections, with services rated as ‘good’ or ‘outstanding’ to be inspected less often with maximum intervals of five years.
In theory, this more targeted approach should cut the number of overall inspections, but simultaneously the CQC has said it is committed to conducting more unannounced inspections.
How these seemingly opposing aims will work together in practice remains to be seen. It may mean a service rated ‘good’ or ‘outstanding’ could, in fact, still undergo a re-inspection within the five-year interval.
Therefore, much will depend on the weight given to these two aims and we will look to see if the frequency of inspections decrease or remain the same.
Implementing a single shared view of quality
The CQC strategy proposes developing a single shared view of quality across the regulators, with a common understanding of what that would look like.
This would require collaboration among regulators and other national and local oversight bodies to share and report on provider quality. It may be ambitious to expect a common meaning of quality, but this should not deter open dialogue and sharing to achieve such a goal.
The CQC rightly aspires towards a position where each regulator identifies which one of them is most suitable to deal with specific concerns. This is something we welcome, as, currently, a doctor may be investigated and censured by multiple agencies at the same time.
There is also a balance to be achieved between consistency and recognition of the varied nature of independent doctors’ services – for instance, managerial structures and resources.
CQC inspections should reflect the fact that independent services are privately funded. Their administration and the use of resources should be assessed differently to an NHS GP practice.
Therefore, the appropriateness and necessity of the CQC’s question about an independent doctor’s services’ ‘effectiveness’ is redundant.
We believe the CQC’s rating of independent services should only reflect the care being provided to patients.
We foresee a number of practical challenges for the CQC if it wishes to begin rating independent services in the future, given the sheer scale and number of specialties in this sector.