CQC Ratings – The Unknown

As providers of health and social care find themselves lost in the strange new world of CQC ratings, we have noted some themes and trends within the ratings currently being awarded by CQC. Currently there is a vacuum where no one really seems sure of exactly how CQC are reaching their ratings and judgements.

They are yet to issue a set of ratings descriptors aside from the brief criteria attached to quality statement scoring criteria. Through supporting numerous organisations through factual accuracy and enforcement challenges, we have seen there is variation between what each inspector deems ‘significant issues’.

We have put together a quick guide below on the trends and themes we have noticed in the way CQC is currently rating in the safe domain and tips on how you can avoid a low score in these areas.

Any issues which affect the safety in a significant way are likely to result in a score of 1. These are ranging from medication errors and poor practice to lack of learning from incidents. It is worth remembering if one quality statement is scored as 1 then this limits the rating for that domain to a rating of requires improvement. Some issues we have seen result in a score of 1 for quality statements in the safe domain include:

Learning Culture

Lack of evidence of lessons being learned and shared effectively after incidents and safeguarding events.

How to avoid this:

• Ensure you are documenting lessons learned from any significant incident and safeguarding event. Don’t wait until the investigation is completed, if there is learning that can be completed immediately makes sure this is done.
• Use a standard template for recording lessons learned and be clear on what the learning is and what needs to be completed to improve.
• Share lessons at all meetings and briefings and keep records of these.
• Keep all your information regarding lessons learned in one place to provide to the inspector.

Lack of evidence of robust incident and safeguarding investigations.

How to avoid this:

• Make sure you have evidence of investigation for every incident and safeguarding event. Simply completing tick boxes on an incident form will not be enough to demonstrate you are effectively investigating events.
• Make sure as much detail as possible is added to incident forms and ensure you have a standard investigation template you can complete for significant events such as falls and safeguarding cases.
• If you are asked for investigation records during an inspection, make sure you clearly explain where these are held to CQC. For example, if your investigation is within the incident form, state this and provide CQC with a copy.

 

Unsecured chemicals or products that may harm people if ingested.

Unsecured thickener powder.

How to avoid this:

• Undertake frequent spot checks for unsecured substances and thickening powder and record these.
• Imagine you are an inspector and try every cupboard and drawer, look at this objectively. Is there anything in these spaces that could cause harm to a vulnerable person? If yes, remove, secure and remind staff.

Providers not referring incidents of a safeguarding nature to local authority and CQC.

How to avoid this:

• Audit your incidents weekly, if possible, check within these audits for any unreported incidents.
• Most electronic care record systems allow key word searches so use this to your advantage. Search for terms such as ‘bruising’, ‘wound’, ‘aggression’ and ‘fall’. Retrospectively report any incidents that have not been already reported.
• Ensure your threshold for reporting any issues of a safeguarding nature is low. It is always better to over report than under.
• Remember the CQC’s requirements for reporting safeguarding events, it only has to be an ‘allegation’ of abuse to require reporting. Failing to have measures in place to prevent a fall for example, could be seen as an omission and therefore this would be an allegation and needs reporting.

 

Care plans and risk assessments not matching in content and not being updated.

How to avoid this:

• Audit your care plans and risk assessments frequently and thoroughly.
• We know this can be tedious but it will ensure people are receiving safe care and will protect your business from receiving a poor rating.
• One of the most common failures in this area is care plans not being updated following changes to dietary needs. For example, a person may require a level 5 diet and was previously on level 6. This may be updated in one section but not in another, CQC have repeatedly scored the ‘involving people to manage risks’ as 1 based on this error.

 

Controlled drugs checks not being undertake and lacking two signatures.

Medication being left with service users to take on their own.

Competencies for specific medication administration not being completed for example buccal and sub lingual medication.

Covert medication plans not being signed off by both the doctor and pharmacy.

How to avoid this:

• Ensure your medication audits cover all areas CQC will look at, this includes covert medication, observing practice and controlled drugs management.
• Covert medication plans must be signed off by both the prescribing clinician and a pharmacist. These plans should include clear instructions on how to administer the medication for example crushing.
• Ensure competencies are in place and completed for all staff administering medication. It is expected that staff undertake competencies for all route of administration they may need to use. So, if someone has buccal medication or sub lingual medication prescribed, you need to make sure your staff have undertaken specific competencies for this route of administration.

We hope this has been helpful, please let us know which domain you would like us to focus on in our next newsletter.