cqc-safeguarding-tmmt

Safeguarding that Stands Up to CQC: A Practical Guide for GP Leaders

To be rated at least “Good” for the CQC safeguarding quality statement, a GP practice needs to be able to demonstrate that safeguarding is embedded in everyday systems, culture and clinical practice – not just that policies exist on paper.

The ‘three Ps’ – the types of evidence that the CQC are looking for – of Policies, Personnel and Patients need to exist to demonstrate that the policies are working in practice and that patients (and your staff!) are actually being safeguarded from harm and abuse.

Thinking about this from a leadership perspective, it helps to break down what the CQC is really looking for, and how you can evidence it:

‘We work with people to understand what being safe means to them as well as with our partners on the best way to achieve this. ​

We concentrate on improving people’s lives while protecting their right to live in safety, free from bullying, harassment, abuse, discrimination, avoidable harm and neglect. ​

We make sure we share concerns quickly and appropriately.’​

Policies:

First, your safeguarding policies for children and adults need to be current, aligned with local multi‑agency procedures and actually used. Inspectors are well aware that many practices have beautifully formatted policies that bear little resemblance to reality. They will test this by talking to staff at all levels, and perhaps patients. Staff should all be able to explain what they would do if they had a concern, or what they have done if that has indeed happened recently. Staff may be asked if they know who the lead is, how to access them and how timely their responses have been in the past.

The chaperoning process is something that will be looked at under this CQC Quality Statement, and practices may wish to refresh their procedures in light of recent guidance in this area. 

Training: 

Training is the next major pillar. From a CQC point of view, it is not enough to say ‘everyone is trained’. A practice will need a workforce training matrix that shows who has done what, when, and at what level in accordance with the relevant guidance. Inspectors may ask to see certificates and will often pick staff at random to ask them when they last had safeguarding training and what they learnt from it. 

Oversight:

Clear leadership and accountability are essential. The practice should have named safeguarding leads for adults and children, with time and support to do the role properly. CQC will expect those leads to be visible and active: attending local safeguarding meetings or webinars where possible, keeping up with changes in guidance, and ensuring learning is fed back into the practice (and minuted!). Practices have been marked down in the past for having no evidence of safeguarding being on meeting agendas (even if there was nothing in particular to discuss) – this is what standing agenda items are for, as they demonstrate the topic is at least being thought about and meeting attendees are being invited to bring up live issues.

Embedding

Where many practices fall down is in demonstrating that safeguarding is woven into routine clinical and organisational work. Safeguarding registers should be reviewed regularly for updates, and cases should be regularly discussed by an MDT.  It also means having robust systems for coding and flagging vulnerable patients and all family members, managing access to these registers so they aren’t viewed inappropriately, and documenting contacts with social care, health visitors, school nurses and mental health teams.

Culture

This is the hardest part, as there is no short cut to having a culture where staff feel free to speak up. How does the practice truly know that staff feel safe to escalate safeguarding concerns? Is it enough to say that staff have been directly asked? The CQC will certainly ask them directly in their interviewing. Should they be asked in a way that they can respond anonymously without fear of being identified for example through an anonymous whole staff survey perhaps? 

Legal frameworks 

GPs and leads should be able to explain how the Mental Capacity Act, Deprivation of Liberty Safeguards, the Mental Health Act and the NHS Sexual Safety Charter apply in everyday practice. Of course that does not mean everyone needs to be a legal expert, but someone should be able to describe how capacity is assessed, and best‑interest decisions are documented. If there is or has even been a patient under a DOLS, then this can be used as a case study to inform team learning on the subject. 

Documentation

Finally, documentation and evidence of learning are crucial. From a CQC perspective, if it is not recorded, it did not happen. As well as the examples listed above, a practice should be able to produce, quickly and coherently:

  • Examples of safeguarding concerns, actions and outcomes (appropriately anonymised)
  • Significant event analyses related to safeguarding, with evidence of learning and change
  • Records of communication with external agencies
  • DNAR records and evidence that these are audited to ensure they are up to date
  • Notifications to the CQC of safeguarding incidents (or an awareness of what type of incidents must be reported to the CQC – incidents where the allegation of abuse is linked to their provision of care)
  • Policies and procedures related to covert medications
  • Policies and procedures relating to children’s appointment DNAs 

In summary, the safeguarding quality statement is not just another compliance hurdle to tick; it is a lens through which the CQC will judge your leadership, culture and risk management. A ‘good’ rating comes when you can show that safeguarding is everyone’s business, that staff are trained and supported, that systems are robust but workable, and that you learn and improve when things go wrong. 

Enhance your clinical services with our Clinical Pharmacists for your PCN, GP Practice, or Federation.

Below are some useful resources from the CQC, if you would like to start working on your compliance in this Quality Statement:

Watch the entire webinar series on our Youtube channel.

Author

  • GP & Clinical Advisor

    I am a practising GP in West Sussex, working six sessions a week with a clinical focus on family planning and reproductive health. Alongside her medical practice, she is a fully insured, CEDR-accredited mediator with over six years of experience in mediation. She earned a distinction-level qualifying law degree while continuing her work as a GP, further strengthening her expertise in resolving complex professional disputes.

Related Blogs