Blog

By Errol Archer, Consultant Solicitor-Advocate at BMA Law

CQC’s current direction of travel regarding primary care inspections should be welcomed by general practice. The regulator is resurrecting its former approach, including more frequent inspections, clearer sector-specific expectations, and more professional judgement, rather than an overly mechanistic scoring system.

For GP practices, the key development is that CQC is proposing a return to the use of an assessment framework and rating characteristics to support their inspections. The rating characteristics will help inspectors to decide on the right ratings for each of the five categories of inspection: safe, effective, caring, responsive and well-led.

It is expected that, by referring to rating characteristics, different inspectors and inspection teams will produce more consistent judgements and ratings across the practices they inspect. This should address current concerns that different practices, apparently demonstrating similar levels of compliance, end up with different category ratings and sometimes with different overall ratings.

CQC’s consultation on the draft assessment frameworks and draft rating characteristics closed in March 2026 and it began a pilot of its new assessment approach in June 2026. This “piloting, testing and evaluation” will run until October 2026. It is important for general practices to be aware that participation in the pilot is voluntary, and practices can insist on being inspected on the basis of CQC’s current inspection approach (i.e. quality statements and scores), if they prefer.

The emphasis appears to be shifting from inspectors looking for evidence of failure to understanding what makes a real difference to patients’ experience of care. In practical terms, this should mean that inspectors are likely to focus heavily on patient access, continuity, safety, clinical follow-up, complaints, staff culture and whether governance genuinely supports safe care. Policies and documents will remain crucial in evidencing compliance, and they should corroborate what is happening in the practice, not substitute for it.

So, CQC will be returning to the previous inspection methodology of ‘looking for good’ during inspections and then providing timely feedback, to practice partners, on their findings.

Practices should prepare now, especially where managers are new or the practice has not been inspected for several years. Preparation should include:

• checking medicines, long-term condition recall and safeguarding systems;
• ensuring significant events, complaints and learning are recorded and followed up;
• reviewing aged ratings and historic inspection issues;
• checking whether minutes of governance meetings evidence actions, not just discussion;
• ensuring staff know what to expect and can explain systems confidently; and
• evidencing the use of patient feedback appropriately.

The return of rating characteristics will prove particularly helpful because it should drive consistency and allow practices to have meaningful conversations with inspectors about their level of compliance. This in turn should support inspectors to exercise professional judgement accurately.

How BMA Law can help

We regularly support practices in responding effectively to CQC draft inspection reports and ensuring that CQC ratings fairly reflect compliance in the practice. If you would like more information on the legal and compliance support, we provide, please contact us on 0300 123 2014 or fill out a referral form here.