Back in November 2017, the CQC issued their updated Key Lines of Enquiry (KLOE). There are 41 new KLOE’s which link to a new approach to inspection. The new KLOEs also align with themes that the CQC have identified as needing improvement based on their experiences. In broad terms they are:
- System leadership, integration and information-sharing
- Information governance and data security
- Technology: For efficiency, accessibility and more person-centred
- Medicines: Robust and safe medicines management
- End of life care: Delivering good quality care at the end of life
- Personalisation, social action and the use of volunteers
- PIR becomes the Provider Information Collection PIC
I think there is going to be more focus on business processes and the systems that underpin them and whether they are effective in improving the lives of the people receiving the care. Owners, Directors and Senior Management will also be under greater scrutiny to ensure there is a good balance of skills and experience in place to manage the business effectively.
Inspections will still be heavily focused on the quality of the service at the point of delivery but there will be more information gathered by the CQC from multiple sources to help guide them on when and what to focus on during an inspection. This market oversight means they will gather information from organisations such as the Health and Safety Executive or Environmental Health plus they will use historical data from previous inspections to see how the service has performed over time.
A key component of Market oversight will be the new Provider Information Collection (PIC). This is an online working document that must be completed at least annually (CQC recommend updating it every 3 months) and failure to do so will result in an automatic Requires Improvement rating for the well-led domain irrespective of how Well-led your organisation might be. So, updating the PIR should become embedded in your daily routines because it will demonstrate your commitment to good governance and effective quality management. Leaving it to the last minute at the end of year does not project a view that your organisation is on top of its record keeping and governance procedures and let’s be honest trying to gather data or capture events from up to a year ago is much harder than something that occurred yesterday.
What all this means in practice is a more holistic- approach to inspection using information from numerous sources that will form an overall picture of how your service is performing. So, providers need to ensure their data capture, recording and reporting mechanisms are effective and robust.
Director W&P Training Ltd