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Being Well-Led in 2019

Find out why practices are failing under this CQC Key Line of Enquiry

Did you know that the CQC’s Key Lines of Enquiry (KLOEs) changed in April 2018?

The reason for this was to condense the existing sets of KLOEs for each type of service (dentists, GPs, etc.) and streamline them into a single set for healthcare. During this reorganisation, CODE liaised closely with CQC over a 12-month period to effectively update the iComply Application.

Whilst, practically, the inspectors are still inspecting in the same way, the main change to note is that the Well-led KLOE has been expanded and focused on more as part of the CQC’s ongoing strategy. You can learn more about how the CQC inspect practices on their website here.

It is interesting to observe that CODE’s research shows that every practice that failed recently has fallen down on being well led, and with this being the area where our research has highlighted the biggest changes, we need to look at this new expanded definition of ‘well-led’ and understand what the CQC are actually looking for…

Much of this comes down to allowing enough time for effective compliance management. At CODE, we recommend about eight hours per week to comfortably stay on top of everything. Not allowing the required amount of time it needs could very easily put you on a path to failing the Well-led KLOE.

It is important to keep compliance time a priority and not allow yourself to ‘get behind’ on tasks – being behind one week rolls over to the next, and before you know it you could be 40 hours ‘behind’. This makes it incredibly hard to catch up and, essentially, being ‘behind’ means you are non-compliant. Also, crucially, when this comes to key tasks such as risk assessment reviews or audits, non-compliant could mean that you are breaking laws.

Have you got the right people in the right roles? Are the people in charge of managing the practice capable enough to do so?

We know that, on the whole, failures under the Well-led KLOE are not due to leaders purposely not carrying out duties correctly, it is often a case of not being up to date with the latest regulations. If the principal is passing on misinformation to those delegated to carry out compliance tasks, you end up with a cascade of non-compliance.

You can delegate responsibility for a task, but you can never delegate accountability because if you’re a registered manager or the practice owner, the buck stops with you.

If you are delegating certain tasks to certain people – such as checking emergency drugs, etc – it is absolutely vital (and often missed) to carry out spot checks. Whilst the staff might be dutifully ticking the sheet, if you haven’t double checked to ensure that things are being carried out as they should be, mistakes may be being made inadvertently. It’s important to remember, delegation requires training, management, and follow up. To help our members we’ve recently added management double checks to our Daily Infection Prevention Checklist (M 257C) and Emergency Drugs and Equipment Check Record (M 254A) templates.

Are the people in your lead roles, including yourself, competent and sufficiently trained to carry out these tasks?

Think about the roles that you give to people. When promoting someone to a role it is your responsibility to ensure that they are trained to carry it out, not theirs, and when recruiting it is your responsibility to check that they are competent. If you honestly don’t know how to meet the regulations, you may never know if a potential manager does. This quote from an inspection report shows how giving a role to someone who doesn’t know how to carry it out correctly can set you up for inspection failure: ‘The lead nurse had used a template supplied to the practice from a compliance company to carry out a risk assessment. However, she had not received training to enable her to competently assess the risks.’

Maintain your reputation
Failing an area of inspection doesn’t necessarily mean the practice will be immediately shut down. Instead, the report will show that a practice was found to be in breach of the regulations and has failed an inspection. This is actually the scenario that you want to avoid because the report will appear online saying that you are poorly managed and unsafe, which, to a local newspaper, could be front page news – highly damaging to your reputation and goodwill value.

If you don’t have a system like iComply in place to help you keep on track, it is worth the investment. This will also help you to stay on top of regulatory changes! In addition, ensure that the key people in your leadership team, and those assigned to compliance tasks, are sufficiently trained and competent in these roles. See our recommended actions below for a good starting point.

Action points 

  • Allocate eight hours per week to compliance management
  • Ensure that those in leadership roles stay up to date
  • Invest in a system, follow it and delegate effectively
  • Train your team (pay for courses where required) and carry out spot checks!
  • Create a culture of quality led by you
  • Gain peace of mind that you are doing it right – from an expert

Peace of mind
How do you know that your compliance is correct and that you’ve understood both the requirements of the legislation along with any recent changes to guidance or CQC interpretation? Most managers we speak to would love the peace of mind that they’ve ‘got it right’ rather than find out when inspectors visit. With this in mind, we are offering 20% off a CODE Compliance Health Check to members and non-members.

During a Health Check, our CODE consultant will review your compliance against the current regulations and legislation, provide you with an action plan and give you guidance on meeting the KLOEs. The health check normally costs £749 for members and £799 for non-members*

Interested? Just give us a call on 01409 254 354!

CODE will be at the Compliance Hub at the London Dentistry Show on 13-14 September 2019. The event is free to attend, so if compliance and management is part of your PDP it is worth coming down to hear the great line-up of speakers we have scheduled, including John Milne (CQC), Karen Penfold (CODE), Sandra Smith (CQC inspector), and Alex O’Neill (CODE)! Click here to register for tickets.


*(Prices quoted are exclusive of VAT)