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16th November 2020

CQC Transitional Monitoring Approach Guidance for GPs (Last update: 16.11.20)

Download our CQC Transitional Monitoring Approach Guidance for GPs here

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Alternatively, read the guidance here: 

The CQC is evolving its approach to regulating as the risks from the coronavirus pandemic change, by using a transitional approach to monitoring services.

The focus is on:

  • Safety
  • How effectively a service is led
  • How easily people can access the service

The new approach includes:

  • A strengthened approach to monitoring, based on specific existing key lines of enquiry (KLOEs) so that risk in a service can be monitored
  • Using technology and local relationships to better direct contact with people who are using services, their families and staff working in the service
  • Targeting inspection activity where there are concerns

Once the CQC have reviewed information about your service, you will have a conversation online or via telephone. This is not an inspection and you will not be rated from this. It will help decide if further regulatory action is needed.

Information considered about a service

The CQC will consider:

  • Previous inspection reports and ratings
  • Monitoring information collected through usual data sources
  • An inspector’s knowledge of the service
  • Views of people who have used the service from online feedback, enquiries, and information from other agencies

Where more information is required, the CQC will contact you for further information.

Monitoring

A call will be arranged with you and can take an hour or two, but some may be shorter. Microsoft Teams will be used where possible, if not a telephone call will be arranged.

The call will be around the specific KLOEs for your type of service and the inspector will note details around the discussion you have, noting any risk areas identified and examples of good practice and improvements to the service.

The inspector may also request evidence during the call and will allow screen sharing or attachments to be sent on an encrypted or protected email. If evidence cannot be sent on the call it must be sent to the inspector within 24 hours of the call. This will only be done where necessary.

Audio recordings will not be taken unless your consent is gained. An overall monitoring summary of findings will be prepared after the call.

The monitoring summary record is not an inspection report and no ratings are given, as such the factual accuracy process does not apply. Monitoring summary records will not be published on the CQC website.

Monitoring Outcome

Where an inspection or other regulatory action is not needed, a copy of the monitoring summary record will be sent.

Where risks are identified to the safety of people using the service, further regulatory action may be taken, including help to find additional sources of support for the service, an inspection to be carried out or enforcement processes. A monitoring summary record will not be sent in such cases and the necessary action will be taken.

Monitoring Questions for Providers

During the inspector’s call they will focus on the specific key lines of enquiry below.

The types of detail asked within each KLOE is also recorded with some guidance from QCS on potential examples, policies and documents in the resource centre to refer to for evidence of these:

SAFE
S1: How do systems, processes and practices keep people safe and safeguarded from abuse?
Potential Evidence 
How do you ensure staff recognise safeguarding issues for adults, children, and other vulnerable people, and that they take appropriate action?*Safeguarding notifications and records

*Feedback from Local Authority/Safeguarding teams

*Safeguarding Adults Policy and Procedure

*Safeguarding Children and Child Protection Policy

*Mental Capacity Act (MCA) 2005 Policy and Procedure 

How do you ensure that the management of any safeguarding concerns does not discriminate people, and that their human rights are protected?* Human Rights and Equality Policy and Procedure

*Consent Policy and Procedure

*Patient feedback

*Feedback from patients’ family or carer

What are your arrangements to respond to medical emergencies?*Resuscitation Policy and Procedure

*Home Visiting Policy and Procedure

Where you have moved to remote consultations (telephone and video consultations), how do you identify vulnerable people or people who might be digitally excluded because of communication barriers (for example, because of a disability or poverty)?*Consultation and Treatment or Care Pathways Policy and Procedure

*Online Consultations Policy and Procedure

*Video Consultations Policy and Procedure

*Use of accessible information to communication

*Patients with Communication Difficulties Policy and Procedure

*Patient feedback

S2: How are risks to people assessed, and their safety monitored and managed, so they are supported to stay safe?
Infection ControlPotential Evidence 
What changes have you made to infection control arrangements to protect staff and patients using the service?*How you made the Practice COVID secure? E.g. screens, revised cleaning schedules, break areas, social distancing with work areas

*Infection Control and Decontamination Policy and Procedure

*Personal Protective Equipment (PPE) Policy and Procedure

*Assessing and Reducing Risk to Workforce (COVID-19) Policy and Procedure

*Coronavirus Policy and Procedure

*Pandemic Policy and Procedure

*Staff Immunisations and Vaccinations Policy and Procedure

*Handwashing Hygiene Audit for Primary Care

*Signage (internal and external)

*Patient notices about social distancing, face coverings and hand washing/sanitising 

*Flu Planning Checklist

*Risk Assessments e.g. Risk of Showing Symptoms of Coronavirus (COVID-19), Risk Assessment for Staff (Including Vulnerable Groups During COVID-19), Staff Immunisations

* The Practice website and social media been updated with appointment, prescription collection and visiting information

How do you ensure staff have the appropriate time for donning/doffing and cleaning between seeing patients? (not relevant to online services)* Personal Protective Equipment (PPE) Policy and Procedure

*The procedures you have in place to allow additional time e.g. longer appointment times

*Staff input and feedback

When was your last audit of IPC/PPE/the environment and facilities? What did it tell you and what actions have you taken?*Infection Control and Decontamination Policy and Procedure

*Audit Policy and Procedure

*Clinical Waste Disposal Policy and Procedure

*An IPC audit has been carried out in the last 6 months

*Any IPC actions are documented and with target and completion dates

Safety systems and risks to peoplePotential Evidence 
What actions have you taken in the last six months as a result of learning from serious incidents to ensure people are kept safe?*Serious Incident Notification Policy and Procedure

*Hazard Reporting Policy and Procedure

*Significant Event Policy and Procedure

*Meetings Policy and Procedure

*COVID-19 Secure Workplace 

*Risk Assessments e.g. Pandemic Threats by Infectious Diseases

*Toolkit (QCS Resource Centre)

*All documented actions discussed at relevant in-house meetings

How are patients who need urgent care and treatment identified, prioritised, and protected from discrimination?*Consultation and Treatment or Care Pathways Policy and Procedure

*Referral Policy and Procedure

*Describe your processes for treating patients who need urgent care

How do you recognise and manage the deteriorating patient? (not relevant to online services)*Home Visiting Policy and Procedure

*Medical Care Communication and Information Policy and Procedure

*Describe how you maintain your list of vulnerable, frail and end of life patients

How do you ensure appropriate staffing levels and skill mix to cope with demand? (For example, weekends, bank holidays, seasonal pressures, epidemics)*Staff Rota Policy and Procedure

*Recruitment Policy and Procedure

*Staff Requirements and Involvement Policy and Procedure

*Locum Policy and Procedure

*Agency Staff Policy and Procedure

*Staff Attendance Record

*Rota Management

*Give details of the staffing hours from the CQC COVID claim form

How are you assessing risks to staff employed through the primary care network (PCN)?*Risk Management Policy and Procedure

*Assessing and Reducing Risk to Workforce (COVID-19) Policy and Procedure

*Staff feedback

*PCN feedback

How do you identify and manage patients who need a face-to-face appointment?*Consultation and Treatment or Care Pathways Policy and Procedure

*Online Consultations Policy and Procedure

*Video Consultations Policy and Procedure

*Describe how patients are triaged and assessed for a face to face appointment

What are your systems to support staff to work remotely where this is appropriate and required?*Home Working Policy and Procedure

*Data Protection and Confidentiality Policy and Procedure

*Data Protection Spot Check Audit

*Employee Welfare Check Form

*Flexible Working Policy and Procedure

S3: Do staff have all the information they need to deliver safe care and treatment to people?
Potential Evidence 
How do you manage clinical records to ensure safe care and treatment?*Consultation and Treatment or Care Pathways Policy and Procedure

*Record Keeping Policy and Procedure

*Medical Record Summarising Policy and Procedure

How do you manage referrals to and from other providers? (not relevant for online providers)*Referral Policy and Procedure

 

S4: How does the provider ensure the proper and safe use of medicines, where the service is responsible?
Potential Evidence
Have you made any changes to your approach to medicines management? (for example, in relation to repeat prescribing, ongoing monitoring requirements for high risk medicines)*Medicines Policy and Procedure

 

If so, what, and how has this affected care?*Describe the changes you have made around repeat prescribing and monitoring high risk medicines
How are people’s medicines reconciled, in line with current national guidance, when transferring between locations or changing levels of care?*Medicines Policy and Procedure

*Patient Registration and Identity Check Policy and Procedure

*Medical Record Summarising Policy and Procedure

Have you made any changes to antimicrobial prescribing? If so, how has this affected care?*Describe any changes you have made and how this has affected care

*Patient feedback

EFFECTIVE
E1: Are people's needs assessed and care and treatment delivered in line with current legislation, standards, and evidence-based guidance to achieve effective outcomes?
Potential Evidence 
How are you identifying, cascading and keeping up to date with changes in clinical guidance?*Primary Care Bulletins

*QCS Resource Centre and Updates

*CQC Updates

*CQC (Nigel’s Surgery) Mythbusters e.g. 97: Responding to coronavirus (COVID-19)

*NHS England website

*RCGP website

*NHS Digital Website

*NICE website

*Meetings Policy and Procedure

*Regular COVID staff meetings

*Staff are provided with regular training and instruction as guidance changes

What are your oversight arrangements for clinical care provided by clinical and non-clinical staff?*Supervision Policy and Procedure

*Medical Care Communication and Information Policy and Procedure

To people in care homes*Home Visiting Policy and Procedure

*Feedback from care homes

*Feedback from Practice staff

To vulnerable people in their own homes*Home Visiting Policy and Procedure

*Feedback from patients

Independent doctors and clinics:Potential Evidence
For clinical decisions made during calls*Describe your arrangements
E3: How does the service make sure that staff have the skills, knowledge and experience to deliver effective care, support and treatment?
How do you ensure that all staff (clinical and non-clinical), including those being flexibly re-deployed, have the skills and knowledge to carry out their roles and responsibilities effectively?*Recruitment Policy and Procedure

*References Policy and Procedure

*Development Appraisal Policy and Procedure

How do you ensure that the staff who deal with patients are operating within the appropriate scope of practice at the point of recruitment, and ongoing? For example, audit of consultations?* Clinical Governance Policy and Procedure

*Supervision Policy and Procedure

*Audit Policy and Procedure

*Completed consultations audit

E5: How are people supported to live healthier lives and, where the service is responsible, how does it improve the health of its population?
How do you ensure that people who are affected by health inequalities are receiving the care they need?*Quality Improvement Policy and Procedure

*Human Rights and Equality Policy and Procedure

*Patients with Communication Difficulties Policy and Procedure

How are you promoting good health/targeted approaches in response to coronavirus (COVID-19) and people at risk?*Information available on the Practice website and social media

*Continuing with health screening programmes such as cancer screening and immunisations

How are you identifying people who have missed screening tests/immunisations? What actions are you taking to promote people to access these services?*Immunisations and Vaccinations Policy and Procedure

*Describe the systems you have in place, such as letters, emails, SMS text reminders

*Practice website and social media

What are your arrangements for your patients to receive flu vaccinations?*Immunisations and Vaccinations Policy and Procedure

*Flu planning checklist

CARING
C1: How does the service ensure that people are treated with kindness, respect and compassion, and that they are given emotional support when needed?
Potential Evidence 
How have you adapted how you support and engage with patients and their families/loved ones (for example, in the context of more remote working)?*Online Consultations Policy and Procedure

*Video Consultations Policy and Procedure

*Feedback from patients and their relatives and carers 

*Staff feedback

C2: How does the service support people to express their views and be actively involved in making decisions about their care, support and treatment as far as possible?
Potential Evidence 
How do you support people to express their views and actively involve them to make decisions as far as possible?*Consent Policy and Procedure

*Patient feedback

*Complaints, Suggestions and Compliments Policy and Procedure

*Patient and Public Involvement Policy and Procedure

RESPONSIVE
R1: How do people receive personalised care that is responsive to their needs?
Potential Evidence 
How do you take into account patient choice about how, when, where they want to be seen? (not relevant to online services)*Consent Policy and Procedure

*Referrals Policy and Procedure

*Accessible Information Standards and Communication Difficulties Policy and Procedure

*Describe the communication methods to show how patients can make decisions about their care and treatment

How do you ensure that people with information and communication needs are able to access appointments and services in ways that meet their needs?*Medical Care Communication and Information Policy and Procedure

* Accessible Information Standards and Communication Difficulties Policy and Procedure

*Describe how you help patients with a Learning Disability to access appointments 

*Provide examples of any adjustments made for patients

How does care provision take account of the needs of individual people? (for example, Trans people, people who have a disability, people with long term conditions or mental health needs)*Equality and Diversity Policy and Procedure

*Human Rights and Equality Policy and Procedure

*Describe how you meet the needs of patients with long term conditions e.g. how you have managed reviews during the pandemic

Have you identified any barriers to care provision, particularly for patients with protected characteristics? For example, disabled people, older people, BAME people. If yes, what actions have been taken to combat them?*Provide examples of issues you have come across and how you have addressed them 
How do you engage with patients who are unable to use the telephone or digital/online platforms, so that you can understand their health needs and offer them care or treatment?* Accessible Information Standards and Communication Difficulties Policy and Procedure

*Appointments Handling Policy and Procedure

*Home Visiting Policy and Procedure

*Describe how you treat patients who need additional support to book an appointment and require medical care 

R3: Can people access care and treatment in a timely way?
Potential Evidence
How are you managing access to services? 
Do you have backlogs of activity and long waiting times as a result of coronavirus? How are you managing this? What are your recovery plans?*Appointment data from your clinical system and telephone system is available
How are you ensuring that high-risk/vulnerable patients and pathways are being identified and prioritised appropriately? (not relevant to online services)*Describe the safety netting procedures you have in place

*Describe how Primary Care Network staff are assisting with this, if appropriate

What are your arrangements to follow-up and support patients whose care and treatment was delayed due to coronavirus? For example, patients with non-coronavirus related issues*Describe how you manage waiting lists for patients whose appointments were postponed during the pandemic
How are you ensuring equitable access to appointments when they are needed, especially for people with protected characteristics and vulnerable groups? For example, Trans people, people who are housebound, people at the end of their life (not relevant to online services)*Appointments Handling Policy and Procedure

*Medical Care Communication and Information Policy and Procedure

*Describe how these patients access appointments 

How do you ensure that patients are receiving appropriate types of appointments to meet their needs?*Appointments Handling Policy and Procedure

*Patient feedback

How are you supporting and working with care homes to ensure patients receive the right care at the right time?*Medical care Communication and Information Policy and Procedure

*Home Visiting Policy and Procedure

*Feedback from care homes

How do you ensure that people are able to register with the practice? For example, refugees, asylum seekers, migrants, homeless people*Patient Registration and Identity Check Policy and Procedure
How is the service working with partners to maintain and improve access? (for example, PCN, third-party providers, carer services, local services such as ambulance service etc)*Communication Policy and Procedure

*Meetings Policy and Procedure

*Describe how you are providing NHS 111 appointments and liaising with the PCN and social care staff e.g. regular virtual meetings

What are your arrangements for clinician call-backs (including online and video) i.e. specified time/date offered to patient? How do you ensure patients are not missed or lost through this arrangement?*Online Consultations Policy and Procedure

*Video Consultations Policy and Procedure

*Describe your safety netting procedures

 

WELL LED
W3: Is there a culture of high-quality, sustainable care?
Potential Evidence 
What actions are you taking to protect and support the health, safety, and wellbeing of staff, particularly those who are high-risk/BAME? For example, coronavirus testing*Risk Assessments – e.g. for Staff (iIncluding Vulnerable Groups during COVID-19) and Risk of Showing Symptoms of Coronavirus

*Give examples of any reasonable adjustments you have put in place 

How do you promote equality and diversity, and check that staff feel supported, respected, and valued?*Equality and Diversity Policy and Procedure

*Staff Retention Policy and Procedure

*Meetings Policy and Procedure

*Staff Feedback from surveys, appraisals, one-to-one meetings, and opportunistic discussions 

What training and support is available for staff using new technology to deliver care? (not relevant to online services)*Training Policy and Procedure

*Home Working Policy and Procedure

*Describe how staff are using and adapting to different ways of using technology to deliver care

How are you supporting staff who work remotely and how are you assessing them?*Home Working Policy and Procedure

*Communication Policy and Procedure

*Describe how you keep in touch with staff working from home

W5: Are there clear and effective processes for managing risks, issues, and performance?
Potential Evidence 
Has your business model/operating model changed since the pandemic? If so, how, and what has been the impact on staff and people who use your services?*Pandemic Policy and Procedure

*Quality audits

*Policies and procedures (COVID-19 Hub) 

*Evidence of good governance i.e. meetings, action plans and lessons learnt

How do you assure yourself that you are providing a safe service? For example, regular audits and increased supervision etc.*Clinical Governance Policy and Procedure

*Audit Policy and Procedure

*Meetings Policy and Procedure

*Evidence actions and learning from any audits and meetings, with examples of how this has driven improvement in the service

How are you monitoring business risks and issues, and what actions are you taking to respond to them?*Risk Management Policy and Procedure

*Risk Policy and Procedure

*Business Continuity Policy and Procedure

What are the arrangements for business continuity? For example, arrangements for diverting calls, contingency planning for staff shortages/outbreak onsite, changes made in light of coronavirus. How are you flexing the service/models of care to adapt to changing circumstances, including second wave of coronavirus?*Business Continuity Policy and Procedure

*Describe how you have reviewed your Business Continuity Plan, what adjustments you have made and what lessons you have learned to put things in place for a second wave of the pandemic and winter pressures

How are you working with partners to review and update local pathways?*Describe how you are working with the CCG, PCN, local Practices and other care providers
How do you ensure oversight and governance of care provided by external staff who are working with your patients? For example, staff employed by PCN or third-party provider?*Clinical Governance Policy and Procedure

*Locum Policy and Procedure

*Agency Staff Policy and Procedure

*Supervision Policy and Procedure

Independent doctors and clinics:Potential Evidence
Have you faced challenges in relation to financial viability? If so, what impact has this had on your ability to deliver the service and what actions have you taken to ensure people are kept safe?*Describe the financial issues and impact on your service
W8: Are there robust systems and processes for learning, continuous improvement, and innovation?
Potential Evidence 
What systems are in place to support people (staff/people who use your services and their families/carers) to speak up and raise concerns?*Complaints, Suggestions and Compliments Policy and Procedure

*Whistleblowing Policy and Procedure

How do you support people to provide feedback?*Staff surveys

*Patient surveys

*Patient Participation Group

*Friends and Family Test

*Online feedback via the Practice website

 

*All information is correct at the time of publishing. Use of this material is subject to your acceptance of our terms and conditions.

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