This is the new home for our blog...
We are going to share ideas and articles here gathered from over a thousand managers and leaders completing "Lead to Succeed" with us, with contributions from our own team of experts, former inspectors and business leaders.
Thanks for all the feedback about last week’s post around handling complaints and potential ways you can overcome any possible challenges. This week, I wanted to give some consideration to another topic that often comes up in the Lead to Succeed (L2S) workshops we deliver - Mandatory Training…
Leading and Managing the Inspection Process (the fifth module of L2S) includes an activity called “Potential Sources of Information for the KLOEs”; this is great for getting people thinking about the many types of evidence available to show the inspector why you are outstanding (think of the sources of evidence document as a starting point which you can add examples and relevant evidence specific to your setting). It is always encouraging to see the long lists of sources of evidence, but the one that always seems to be top of the list is the training matrix. Here’s why…
If you have been in the Social Care sector for a while, you will remember as I do when the inspection body was CSCI, (the previous name for CQC - see below) for which some of our L2S facilitators were inspectors; I’m therefore drawing on their experience as part of this blog. A CSCI inspection was very focussed on whether or not people were trained and up-to-date, mainly because the training and its frequency were stipulated in the legislation.
When CSCI became CQC, both the inspection process and legislation changed via the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, to be precise, which changed the emphasis to “Competence”. Those of you who know the regulations will know that regulations 5 and 19 “fit and proper persons” include: providers only employ 'fit and proper' staff who are able to provide care and treatment appropriate to their role and to enable them to provide the regulated activity.
Going back to that activity in module 5, why is the training matrix still the first thing that appears in the sources of evidence activity? It was probably the first thing during the CSCI days to be asked for, yet CQC inspectors spend much more time observing what is actually happening in practice (you will recall we talked about SOFI in an earlier post.) Managers who complete L2S with us regularly share that inspectors have arrived at 6.30am and talked to the staff finishing the night shift; have arrived at lunchtime and had lunch with the residents; and, have been on visits with staff in domiciliary settings. This is very different from the previous paper-based, mostly office-based, version of inspection, although occasional stories of inspectors staying in the office and not carrying out observations still circulate.
To achieve outstanding in this area, we recommend that you evidence to CQC and possibly your commissioners and internal auditors, that not only have staff been trained, but also the learning journey you have taken them on and how they continuously improve and learn on an on-going basis. You all know the expression “you learn something new every day” or “every day is a school day”. The most important aspect of any kind of training is that they are putting what they have learned into practice, every day with the people they support. Otherwise, what is the point in investing time, money and effort into training?
Training is only a piece of the jigsaw as the learning that happens as part of that process is much more important and the competence that follows is even more important, which is why in the recent Skills for Care publication “Mandatory Training”, it clearly recommends that “knowledge and competence should be assessed at least annually”. You therefore need to consider what you have in place to capture this crucial piece of the puzzle.
One of the critical pieces of evidence CQC are looking for is that of continuous improvement; just ensuring your training matrix is up-to-date does not achieve this. Making sure every member of staff has had the necessary training to do their job safely sounds like the first step on the journey to meeting the regulations, but given that the regulations also include Regulation 18 which states: “To meet the regulation, providers must provide sufficient numbers of suitably qualified, competent, skilled and experienced staff to meet the needs of the people using the service”, there is much more to it than just being “up-to-date”.
There are many different pieces of evidence that can show why you are outstanding, often demonstrated by the long lists of evidence that managers come up with during the “sources of evidence” activity, proving that the training matrix is just scratching the surface. One great tip is to collect all of those sources of evidence together into a “One Drawer Inspection Kit” (also in module 5 - Lead to Succeed), which is the subject of next week’s blog.
Dealing with complaints during a CQC Inspection
Hi everyone and welcome to the blog for this week. We were going to cover a topic different to this, however there was a comment on last week’s blog (via LinkedIn) which I thought was important to pick up on before moving on. If you didn’t see it on LinkedIn, this is the comment below (from Eddie Stevens):
“A recurring conversation I have when I run workshops is with unhappy registered managers who are challenging a rating that was negatively impacted because an individual complained directly to the inspector during the feedback stage. The common theme here is that the service knew about the complaint and had evidence to prove they had responded and dealt with this appropriately and robustly, but the inspector somehow missed this.
As a provider it is vital to proactively share these complaints with CQC, in particular those which have been vexatious or not resolved to the satisfaction of the individual, along with details of any action plans or support which has been put in place to support the individual as a result of the complaint. By sharing them in this way, it puts the provider on the front foot and ensures the inspector can join-up the feedback they have received with the records available. It also demonstrates an Outstanding approach where the individual is at the heart of the service and is truly listened to and empowered.”
In brief, Eddie is part of the team at Grey Matter Learning and part of his role is delivering the workshops that he describes at the beginning of his post. So, he is regularly in front of rooms full of managers just like you, listening to their challenges and hopefully sharing solutions.
Okay, so let’s pick up the first point, “unhappy managers, challenging a rating”. This is also something we cover as part of our delivery of Lead to Succeed, Module 5 of the Skills for Care leadership and management programme (Leading and Managing the Inspection Process). As Eddie suggests, it is vital that, during the short time the inspectors are with you, you ensure that they can find, or you show them, the evidence about your service. This is because, once they leave, you can only challenge factual errors or omissions, which means if they don’t see the evidence ON THE DAY, it becomes harder to challenge a rating. Think of it as closing the gate after the horse has bolted which means you are then on the back foot.
In future posts, we will share ideas around the “outstanding log” a way to make sure you have a collection of evidence “ready to go” that makes what I have described above more straightforward.
Next, “someone you support complained directly to the inspector”. Be prepared for this - remember in last week’s post when we talked about the inspection methodology and how the inspectors will talk to the people you support and your staff? This can easily happen. By preparing both your staff and the people you support for what is going to happen during the inspection, you can potentially avoid this happening.
Eddie then describes a common theme regularly shared by managers that “the service knew about the complaint and had dealt with it and had the evidence, BUT the inspector somehow didn’t see that evidence”.
Thinking back to what I said earlier about what you can challenge after the inspection is limited (the appeals documentation even limits the number of characters you can add to it), it is imperative that you get the evidence in front of the inspector when they are there. For instance, if you know that someone you support is not happy with your resolution or the actions you have taken, perhaps you can ask you inspector for advice, this is the situation, this is what we have done, have we missed anything? Bear in mind, you may not want to wait until the actual day of inspection to do this; you can ask this kind of question anytime and really get on the front foot. Being open and honest is a foundation for trust not only between you and your inspector, but also with your team and the people you support.
Therefore, as Eddie mentioned, if you “share the particular complaints that have not been resolved to the satisfaction of the person and share your action plans”, you can seek an alternative perspective on the same set of circumstances.
In doing so, you set the tone for the inspection, so you can then support the inspector to join the dots with what they have seen, heard and been told, demonstrating that you are open and transparent. This then instantly moves you from the back foot to the front foot, ensuring that the inspector sees all of the fantastic work you and your team do every day, backed up by robust evidence of competence.
You can see the original post here: https://www.linkedin.com/pulse/cqc-inspection-methodology-sarah-knapp/
CQC Inspection Methodology
Following on from last week’s blog about the PIR, this week I want to look at what CQC will actually do whilst they are on site with you; in other words, what is the “Inspection Methodology”?
This is taken directly from module 5 of Lead to Succeed, the Skills for Care leadership program that Grey Matter Learning is accredited to deliver. So let’s take a look at the methodology, as follows:
Let’s look at each one in turn:
Planning. Firstly, CQC will plan their inspection before they arrive, using what you have put in the PIR. Using any feedback they have captured (notifications and alerts etc), they will also look at previous inspection reports and much more. This means that, by the time they arrive, they will already have formed opinions about your service and will have ideas about the kind of evidence they are expecting to see in order to form their judgement about your rating.
Therefore, it is vitally important to find ways of communicating with your inspector on a continuous basis so they have plenty of information available to them to support their planning process, but also so they have more than the “on paper” view of your service. For example, if you (or your team) came up with an idea that you felt would improve your service, why not share it with your inspector, who else has done this? Ask them if they think there are any obvious pitfalls or things you might have missed; alternatively, do they know anyone you could contact for advice?
Gathering feedback. This too will take place before the inspector arrives, in so much as they will talk to the people you support and sometimes your staff (using the information you put in the PIR) to collect objective feedback about your service and to contribute to the planning process. Bear in mind that they will not limit who they speak to, i.e. just to those people you include in the PIR; they are likely to include the Local Authority, commissioners, the safeguarding team, potentially the Fire Service or Environmental Health.
Talking to people. On the day, CQC will talk to the people you support (wherever possible) and so it would be prudent to discuss this with the people you support so that they know who the inspectors are, what might happen whilst they are there and what they are there to do. But rest assured, they will talk to as many people as possible to build a clear picture of your service, therefore this is going to include your staff. What can you do to prepare your staff? Have you seen the questions in the CQC document “Prompts and Characteristics”, because it contains lots of questions that might provide some clues:
If we start to look at the order of the inspection methodology, we are halfway through and the manager(s) has not had a great deal of involvement. So if CQC are going to plan what they do before they arrive and gather feedback, as well as talk to the people you support, is there a way you can do the same? CQC have shared their “process”, their methodology, so let’s use it to prepare and make the actual day of inspection less scary for everyone.
I am sure you will have seen “How CQC regulate Adult Social Care”, but it has recently (at the time of writing) been updated and contains lots of useful information to support you to prepare.
We will share ideas on some of the tools you can use to do this in future posts, but the key here is preparation; like I said in our previous blog, don’t wait until two weeks before inspection to “get ready”, because there will be huge volumes of evidence available. All you need are methods for capturing it.
Observation. I am sure you are all aware of SOFI (Short Observation Framework for Inspection) which is “how” the CQC will carry out the observations. Some managers during the Lead to Succeed sessions have shared how they have had two (or sometimes more) inspectors and one “just sat in the lounge and watched what was going on” whilst the other inspector was with the manager or the staff.
For those of you who are familiar with Dementia Care Mapping, SOFI works in a similar way: recording observations every two minutes for a period of approximately 20 minutes to capture a holistic view of the service delivered and, most importantly, the reactions and interactions with the people you support.
So if CQC are going to “talk to people” and use “observation” as described above, can you do the same to get your staff ready for what is going to happen when the inspectors arrive? Many of the managers who have completed Lead to Succeed already use things like “spot checks” and “quality audits” to check performance. However, if during a team meeting you outlined to staff what is going to happen and how you’re preparing for it, then there is no need to worry when CQC are here - “just do what you normally do” should be the message. We are going to talk about “business as usual” in a future blog.
Talking to staff. This is the bit that most people find challenging. You know “that” member of staff that will say they have never had supervision, because you call them “one to ones” and CQC call it supervision (more about that in a future post too). Many managers have shared that one of the questions CQC are likely to ask is “what do you think of your manager?” I suspect this question is asked to find about “well led” and the KLOEs that support it, rather than whether or not people “like” their manager. Therefore, as we know that CQC are asking this kind of question, why not include it in supervision and support your staff with the answer?
However, there are a wealth of resources available from CQC that outline the questions the inspectors will ask. The five “key questions” are by their very nature questions and the CQC doc “sources of evidence” and the “KLOEs” all contain questions. So if we know that CQC are going to ask questions and we know what those questions look like, maybe we can start “practising confidence”. Confidence is key when staff are answering the questions that CQC ask. We therefore recommend, either in team meetings or during the spot checks we talked about earlier, ask your staff questions! In doing so, you can support your staff to be confident in their answers and you can coach them where appropriate, which is a great way to take the “nerves” out of the situation on the day.
Reviewing records. I always find it interesting that reviewing records is last in the list, but I also believe that it is last for good reason! CQC will do all of the above and build a picture of your service and THEN check that the paperwork matches up with what they have seen, heard and been told. This means there is a good chance that by the time they get to the paperwork they will already have a rating in mind and the paperwork is just an opportunity to find more evidence to support the rating they have in mind.
Follow the blog for future posts about each of the individual stages outlined here.
Well, if you read their document from November 2017 on how they will monitor, inspect and regulate Adult Social Care services, it would suggest that by now we should all be using a PIC (Provider Information Collection). However, according to the most recent document released by the CQC (click here), it seems that this is no longer the case, which is what I want to talk about today...
It looks like the CQC are going to stick with the original name of PIR (Provider Information Return)...
Is this a good thing?
Well, from what I can see, it could be. Why? Because, going forward, it’s going to pick up on some of the elements which they had hoped to introduce with the PIC (outlined in Nov 17 version) which I liked the look of...
For example, completion will be on an annual basis – good, because it’s a lot easier to keep on top of things rather than waiting for 2 or 3 years before updating the information about your service. Who remembers when & why they changed an ‘agreed way of working’ 18 months ago because it now feels like it’s always been like that? This of course means we miss out on recording some crucial evidence of continuous improvement! It’s a real shame that it will only be available on an annual basis, as opposed to being constantly available to update (maybe even forming part of our monthly QA checklist). I liked the idea of it being available to update quarterly, if not more often – it supports the formation of good habits.
Another addition to the new PIR process is that if the return is not sent back to CQC by the advised deadline, the best rating you can receive for Well Led is “Requires Improvement”. I love the idea of this; why wouldn’t you want to make sure you reply in good time? Like it or not, in everything there are consequences; this is one of them.
There’s some good guidance around on how to complete the PIR e.g. this document hasn’t long been published and will keep us on track with not only the question coverage, but also gives some hints and tips on how to complete it and it also gives some rationale behind the guidance.
Page 15 reminds us all of the AIS. “The what?” I hear some of you ask…this relates to the Accessible Information Standard (which happens to have been around for a few years now – but I’m still hearing from people that they’ve never heard of it!!!). So now that you’ve heard of it – are you compliant? Do you have good robust evidence to show your regulator?
And whilst we’re at it, are we all up to speed with the Protected Characteristics? Can we even remember how many of them there are? We might be good at being able to evidence equality & diversity for the people we support – but what about towards our staff? I know a manager who was unable to answer this when asked by her inspector…what evidence do you have available to you?
Residential PIR click here
Community Services PIR click here
If you want to know more about Grey Matter Learning and why we care about Social Care, follow our facebook page for more updates. https://www.facebook.com/greymatterlearning.co.uk/
Ever driven down the High Street or around the local Business Park and seen a banner outside the local care provider with “We are inadequate” in huge writing? Probably not, given that no-one wants to publicise they have work to do, or that their service is not as it should be.
But let’s not underestimate how important a successful inspection is, not just because you don’t want to get that banner made for your setting, but because you want your inspection to be a success so staff are proud to come to work, families recognise you as the local provider of choice and your hard work is recognised externally.
If you have just received your PIR/PIC and think that CQC are “due”, think again. There is much more to the PIR (Provider Information Return) than meets the eye, because CQC will use it to risk assess which providers get inspected and when. This means that if you do a good job of your PIR/PIC (Provider Information Collection), you have the opportunity to show CQC that you are doing a great job and are therefore not a priority for inspection.
So, if you leave “getting ready for inspection” to when you first receive your PIR/PIC, you could well be missing out on a wealth of evidence that could tip your service into “Outstanding”. Over the coming weeks in this blog, we will be exploring feedback and ideas from real managers, just like you, who have shared their experiences as part of our delivery of “Lead to Succeed”, the Skills for Care leadership and development programme.
The starting point is: don’t wait for the PIR/PIC or until two weeks before inspection to “get ready” - be “inspection-ready” at all times by coaching staff for what will happen when the inspectors arrive so they are also ready. Even more critically, find ways to capture and record the reasons you are outstanding on a continual basis. Stick with us - we’ll be sharing ideas on this very issue over the coming weeks.
To set the ball rolling, the first idea is to create a “one drawer inspection kit” (more can be found in module 5 of Skills for Care - Lead to Succeed). During many sessions, managers have shared their experience of inspection (not just CQC, but internal quality audits and Local Authority contract monitoring visits, etc). These are along the lines of: “They came when I was on holiday!!!” Imagine the inspectors turn up whilst you are on holiday; do your staff know where all the evidence is? Could they support the inspectors whilst you aren’t there? Well, the “one drawer inspection kit” is a simple tool to empower staff and colleagues to do just that and to give you some peace of mind at the same time.
Choose a place that contains a set of signposts to all the evidence that the inspector might want or need (relevant to your setting/regulations/registration). That way, if the inspectors arrive whilst you are on holiday, your colleagues are already coached to say the following: “Our inspection kit is here. In it, you will find lots of reasons why we are outstanding and, if you need anything further, I will be available in x location”. Future posts will include “business as usual” when the inspectors arrive...
Think of it this way: the “one drawer inspection kit” is a way for you to evidence all of the amazing work you do, day in, day out, and why wouldn’t you want to make absolutely certain to get that evidence in front of the inspector on the day?
If you want to know more about Grey Matter Learning and why we care about Social Care, follow our LinkedIn page for more updates. https://www.linkedin.com/company/1298179/