Hempsons CQC Q&A series: What are some of the basic things care providers miss? 


By Philippa Doyle | August 21, 2025

Last Updated on August 21, 2025

In the first of a new series of blogs, Philippa Doyle, Head of Social Care at Hempsons, answers the most common questions providers ask when dealing with the CQC. 

When it comes to CQC inspections, certain areas are repeatedly flagged as falling short, often because they seem deceptively simple or become lost amidst more complex priorities.  

Here is some further detail on each of the most common pitfalls: 

Breach of Regulation 9: Person centred care

Providers sometimes fail to deliver genuinely person-centred care – this goes beyond just having care plans that mention preferences or routines. Inspectors want to see clear evidence that services are shaped around the individual’s needs, wishes, and aspirations. This includes involving people (and where appropriate, their families) in decision making, adapting activities and routines to suit each person, and respecting unique cultural, religious, or communication requirements. Failure to demonstrate this can indicate a lack of meaningful engagement with those receiving care. 

Breach of Regulation 12: Safe care and treatment

Safety is fundamental. If a service is going to be prosecuted by CQC it is usually due to failure to deliver safe care and treatment. Common issues include unclear medication processes, incomplete, outdated or contradictory risk assessments, poor infection control or not acting on known risks. Providers may overlook regular reviews of care and risk or not respond quickly enough to changing needs. Inspectors are looking for robust systems that make sure people are protected from avoidable harm, with prompt and appropriate responses to incidents or changing circumstances. 

Inconsistencies between care plans and other documents

Care plans, daily records, medical notes and risk assessments should all tell a consistent story about an individual’s needs and support. Discrepancies – such as a care plan stating someone is mobile, but daily notes reporting they need assistance – can suggest poor communication, lack of staff understanding, or that records are not being kept updated. Consistency is key to ensuring safe, coordinated care and demonstrating compliance. 

Not having up to date risk assessments

Risk assessments are only useful if current. Outdated documents may not reflect recent changes in a person’s health, environment or behaviour, potentially exposing them (and staff) to harm. Regular review and documentation are essential, particularly after incidents, changes in condition, or following professional input. Inspectors want to see a clear process for keeping risk assessments under review and evidence that they inform day-to-day practice. 

Not being able to demonstrate preferences

Knowing what a person likes, dislikes or values is central to delivering good care, yet sometimes providers cannot clearly show how people’s preferences are identified, recorded and respected in day-to-day practice. This might mean not capturing information about food choices, routines, hobbies or religious practices, or not following these in practice. Evidence should be visible in care plans, daily notes and observed interactions. 

PRN protocols not updated

‘As needed’ (PRN) medication protocols must be up to date, specific to the individual, and reflect current guidance. Outdated or generic protocols risk inappropriate administration of medication and do not support staff to make safe decisions. Inspectors will look for protocols that are regularly reviewed, clear about when and how medication should be given, and that staff understand and follow them. 

Missing Best Interests (BI) decisions

BI decisions for those who lack capacity must be clearly documented, showing who was involved, what options were considered and how the individual’s wishes and feelings were taken into account. Missing or insufficient BI documentation can indicate non-compliance with the Mental Capacity Act and poor safeguarding. Providers must have clear records of best interest meetings, assessments and outcomes. 

Missing Mental Capacity Assessments (MCAs)

Failure to complete or document MCAs can lead to significant compliance issues. Inspectors expect to see clear evidence that capacity has been assessed appropriately, particularly when individuals are making important decisions about their care and treatment. Each assessment must be decision-specific, and best interests processes must be followed and recorded where relevant. 

Missing assessments

Omitting essential assessments – such as nutritional, mobility, falls or pain assessments – can mean that risks are not identified or managed properly. Comprehensive assessments are vital for developing effective care plans and ensuring that people’s changing needs are recognised and addressed in a timely manner. 

Missing protected characteristics

Providers sometimes overlook recording or considering protected characteristics (as defined by the Equality Act 2010), such as age, disability, gender reassignment, race, religion or belief, sex and sexual orientation. Failure to recognise and address these can impact the provision of truly personalised and non-discriminatory care. All staff need to be familiar with this terminology too – CQC inspectors will often ask – and if staff do not know the term, may unwittingly let the service down, even though they know how to support in practice. 

Missing end of life discussions

Not holding or documenting conversations about end of life wishes can result in care that does not align with an individual’s preferences or values. CQC expects to see sensitive, proactive advance care planning that involves the person and, as appropriate, their family, ensuring dignity and respect at every stage. In many cases people do not want to have that conversation – it is important to demonstrate to CQC that you have tried, but equally that you are respecting someone’s wishes.  

Not documenting all the good work going on in the service

Many providers deliver excellent care but fail to record this consistently. If positive interactions, creative activities or proactive risk management are not documented, they cannot be evidenced during inspection. Good documentation demonstrates safe, effective practice and helps build a strong case for a positive rating. Staff are your biggest asset and can showcase to CQC how your service operates – they will be doing good work every day and making a difference to people’s lives – get them to record one positive experience every day – no matter how small – it really makes a difference. 

Equipment checks – bed rails

Failing to regularly check and record the safety and suitability of equipment such as bed rails can lead to avoidable harm. Inspectors look for evidence of BI decisions, engagement with occupational therapists and district nurses, your own risk assessments around use of bed rails, frequent checks, maintenance logs and swift action to address identified issues, showing a proactive approach to safety. 

The route to a good CQC rating is good paperwork – ensure everyone you support is regularly reviewed and all paperwork is up to date and consistent. High-quality, consistent documentation underpins safe, effective care and is a cornerstone of a positive CQC inspection. Regular reviews, updates and auditing of records ensure that information is accurate, risks are managed and staff can deliver coordinated support aligned with the individual’s evolving needs. 

Medication management

  • Body maps – these should be used for accurate recording and monitoring of any wounds, bruising or areas where topical medications are applied. Up-to-date body maps aid in safeguarding, medication management and transparency in reporting changes or concerns. 
  • Creams – topical medication administration should be clearly documented, including when and where creams are applied, who applied them and instructions for use. This ensures safe use, prevents missed applications and provides evidence of compliance with care plans and medical instructions. 
  • Patches – make sure daily records are kept demonstrating the patch is still in situ, alongside your body maps of the location of the patch. 

Navigating the CQC: A toolkit for social care providers 

Hempsons has partnered with Care England to develop a comprehensive toolkit and training that thoroughly analyses each of the 34 quality statements in the single assessment framework. The toolkit has been created by Head of Social Care at Hempsons, Philippa Doyle, whose invaluable experience with CQC equips her with a profound understanding of the regulator’s inner workings and processes. Find out more. 

CMM’s CQC resource page 

Sponsored by Hempsons, this resource page is a one-stop-shop for care providers’ regulatory needs. For breaking news, newly published guidance, informative blog posts, a monthly column from the regulator, advice on preparing for an inspection and more, click here. 

About Philippa Doyle

Philippa leads Hempsons’ social care team, specialises in CQC work and has significant experience of working both for and against, which gives her a unique insight and the ability to offer pragmatic advice. She has over twenty years’ experience in the health and social care sector and with a varied workload including information governance, safeguarding, Court of Protection and consent. She provides extensive registered manager training to aide compliance with the CQC’s fundamental standards.