CQC Provider Information Return

Is the CQC PIR an evil omen or a time to shine?

Stuart Prince
Special Advisor at Age UK

Mostly maligned, often dreaded, the CQC PIR always used to be the sign of impending doom – you were about to be inspected! The Care Quality Commission were going to descend on you like a pack of hungry Death Eaters and suck the life out of you and your staff in a single afternoon.

Oddly though, the CQC PIR was rarely seen as a weapon with which to defend yourself. So, let’s explore how we can turn it into a Sword of Gryffindor…or at least into something shiny.

Relax, the PIR is now due annually.

Firstly, it is no longer actually the harbinger of doom at all – the PIR is no longer sent out ahead of an inspection in the way it used to be. The PIR is now done annually, on the anniversary of your first inspection. CQC will send you a link to follow to fill in the PIR but you will only have 4 weeks to get it done. If your first reaction is to rattle through it just to get it off your desk, then you are indeed missing a magic trick.

Because of this new approach from CQC, you can work out when it is going to land. This means you can be prepared beforehand by cracking on with a practice version of it. Download a base copy of the CQC PIR from their website, you can effectively work on it all year before you need to send the real one-off. Therefore, you can really polish it and hone it to perfection, because this is your chance to show a CQC
Death Eat…Inspector how great your service is – before they even get there.

This is invaluable if you have a new inspector, or if you just have a service that doesn’t especially fit well into a pigeonhole – such as Foot Care or an End of Life service. CQC inspectors have been
known to struggle with how services like that should be inspected. The more they know about you before they arrive, the better.

Section 1 – Changes.

Let’s take a look at some of the more challenging sections of the CQC PIR. For the purposes of illustration, we’ll look at the Community Services version and the Residential Version, which are in any case virtually identical until you get to Section 6 on Quality Assurance.

It gets interesting from the off really, with Section 1 – Changes.

This is exactly why you should practice this and give yourself time to answer. It’s like writing practice essays before your exams. This section is on what changes you have made to your service in the last 12 months and what changes are planned in the next 12 months, but actually, the key term in these questions is impact. They are actually asking what is the impact of these changes on the people you support. So, don’t bother describing in great detail that new accounting system or electronic support plan app you purchased and installed at great expense and effort – think instead about how it improves the service for people.

Does it mean you’ve eliminated invoice errors and identified needs that weren’t visible before?

Does your change mean your team is more responsive to variations in people’s needs and you are now 100% confident people will always get the right meds all the time?

Consider even the smallest of changes you’ve made if it means it has had a positive impact on people’s experience.

A word of caution here though. Don’t ever make it up! Never put anything in your CQC PIR that you can’t back up with factual evidence or actually show an inspector. You can big up your service by all means, but if the reader likes the sound of it, they may ask to see it or be shown the improved outcomes etc. so make sure you have the evidence.

Dignity, fairness, respect, autonomy and equality.

Equally, if you state that 8 people for example who use the service have a communication need or a specialist diet:

  • Make sure your documentation not only supports that fact, but also;
    • Shows how you are working with all of them to ensure they get are not disadvantaged in how they receive, or give communication to your staff,
    • Demonstrates how they get meals that are appropriate, healthy, varied, and of their own choosing.
  • Don’t make a rod for your own back by failing to adapt your service to meet needs you have actually identified, because your inspector will (quite rightly) beat you with it!

Similarly, you’re asked about recording information about Safeguarding, Notifications, Use of Restraint etc. Make sure that any numbers you put in are backed up by documentation and can withstand cross-referencing because again, you can be sure that the inspector will do this.

We’re still only on Section 2 – and it’s not done with you yet. You’ll next need to describe how you have improved the service to meet the needs of people with protected characteristics as well as how you implement and apply human rights principles. The devil is in the detail here, just think about your service-users and try to think about one or two in particular with protected characteristics where you have made changes to the way you support them.

If you really can’t think of anything you have done, then at least think of something you could do, implement it and record it. Same with human rights – if you can’t think of anything around dignity, fairness, respect, autonomy and equality that you currently do, then your practice version gives you time to implement something. Just don’t say you do it when you don’t.

Don’t forget to collect the data.

There are many questions in the CQC PIR which require you to put in a number or a date and so on. These should be easy, but just make sure in your practice version, that if there is a question on data you don’t currently collect, that you make a point of starting to collect it. This way, when you are asked to fill in your real PIR, you will at least have some data to put in here.

Quality Assurance.

Section 6 is the next one requiring deeper thought – Quality Assurance. The residential version is more straight forward here, whereas its community services cousin is a more open question around how quality is assured in your service. The key here, as with many other similar questions in the PIR, is to be clear, open and honest about what you do – don’t exaggerate, don’t embellish.

Recording and learning.

You could really go to town on this one though – like Q1 it is a good opportunity to show off your service and how you adhere to a continuous improvement principle. Consider describing working practice – supervisions, training, competencies, team meetings.

Then move on to event processing.

Whatever your processes, make sure they show a clear link between recording and learning.

For example, let’s look at a typical Complaints procedure. A complaint comes in, it is then logged, a holding response sent, it is investigated and an outcome letter is sent (within policy timescales of course). Learning from the complaint is not only considered, but also clearly logged. With any change in operational practice communicated to staff, and customers as appropriate and even summarised in your letter back to the complainant.

How to show to CQC that your service is positive and progressive.

A similar approach basically applies to Safeguarding alerts, serious incidents etc.

Don’t forget to show your learnings from these examples. CQC will love this and think of your service as positive and progressive before they even knock on your door.

Have you got a tool that allows you to monitor all of these events and track them fully through your procedures as per your policies?

No?

Create one. Have you got a self-assessment quality audit tool of some kind, that uses the Key Lines of Enquiry (KLOEs) as a basis for challenging your service and its managers on how well you stack up to the minimum standard, which after all these days is Good, not the old-style Satisfactory?

No? More difficult to create yourself, but you can buy in this type of QA support.

Another good reason to start your CQC PIR early.

Section 6 will also ask you about meds errors and safety incidents – again really make sure that whatever you put in here, you have the full documentary evidence for in the office. They will want to see it.

Whilst you are at it, make sure that any Notifications to CQC were done and any that involved Safeguarding were duly reported. A good reason to start your PIR early is that you can start to link these things together now, whilst you still have months to go before you are asked for the real version.

Whilst the residential version ends here, the community services version moves on to Supported Living and Extra Care, where a section then follows on restraint and deprivation of liberty. Once again, make sure your ducks are nicely lined up and don’t describe anything you don’t do and make sure if you are doing it, it’s properly recorded. The second of these is probably a worse sin than the first.

If you’re not sure, a practice version gives you time to find out. There is a question here on whether any deprivations of liberty have been authorised by the Court of Protection. You don’t actually have control over that, but just make sure you can clearly document all of the times you prodded and pushed your Local Authority to process your DoLS referrals, and that you kept on doing it every six months or so – just doing it once won’t cut it.

The Sword of Gryffindor is double-edged.

So there, you have it.

In some ways yes, just a means of asking some statistical questions. But the other, more open questions are not there to catch you out. They are there for you to show the inspectors how good you are, how positively you impact upon people’s lives, how you seek to continuously improve and of course, to allow CQC to get to know your attitudes to these key issues ahead of any visit. The Sword of Gryffindor is double-edged though – if you lie, embellish or unwittingly describe things that you should have covered and have not, then it will work its magic against you.

After all, doesn’t it come to those who are worthy of it?

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