Clinical Audit in Dental Practices: What CQC Expects and Which Audits to Run
Clinical audit in dental practices is one of the clearest signs of a well-led service. As a CQC inspector for 12 years, I saw lots of audits. The weak ones were forms filled in once and filed. The strong ones had an action plan, a named person for each action and a re-audit that showed something had improved. In this guide I explain what CQC expects, which audits are essential and how often to run them.
The CQC mythbuster on audit
The relevant guidance is Dental mythbuster 17: Audit and improvement in primary dental services. I checked the number on CQC's live site, and it is mythbuster 17. CQC updated it in May 2024 to combine audit with quality improvement and peer review.
CQC says it expects providers to be involved in audit or quality improvement to demonstrate good governance under Regulation 17, to deliver care safely under Regulation 12, and to keep premises and equipment clean and maintained under Regulation 15. It also notes that you may need to carry out specific audits as part of your NHS contract.
On inspection, CQC may ask for evidence of three things:
The audit data collection.
The action plan.
The subsequent action taken.
That third point is where many practices fall down. An audit without action is just a survey.
The essential audits
Mythbuster 17 splits audits into essential (must do) and desirable (should do).
Infection prevention and control: every six months
CQC says complying with HTM 01-05: Decontamination in primary care dental practices shows you have valid quality assurance systems. As a minimum, you should audit decontamination processes every six months, with further review depending on the results.
The infection control audit should cover the whole process, from instrument transport and cleaning to sterilisation, storage, surgery cleaning, hand hygiene and waste. My posts on dental infection control and HTM 01-05 and what CQC inspectors check in dental infection control go into more detail.
Radiography
CQC says both the Ionising Radiations Regulations 2017 and IR(ME)R 2017 place a legal responsibility on practices to establish and maintain audits for dental radiology. It points to section 5.4.2 of the Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment, endorsed by CGDent, for how to carry out the audit.
A radiography audit usually looks at image quality grading, justification and reporting in the records. CQC's own worked example in mythbuster 17 uses an FGDP standard of 90% diagnostically acceptable film radiographs. In the example, a practice found a lower rate, traced the problem to an X-ray arm that would not stay in place, had it serviced and agreed to re-audit six weeks later. That is exactly the kind of cycle I wanted to see. Set your audit interval in your radiation quality assurance programme, following the guidance notes and your Radiation Protection Adviser's advice, and stick to it. See my guides to radiation protection and dental radiography compliance.
Accessibility
Mythbuster 17 says all organisations providing services to the public must audit their facilities and ensure they comply with the Equality Act 2010. This is often forgotten, but it is listed as essential.
Desirable audits
CQC lists these as desirable:
Antimicrobial prescribing.
Clinical record keeping.
Other audit topics suitable for your practice.
Record-card audits
I would treat the record-card audit as close to essential. CQC's Dental mythbuster 8 on dental care records says that if records audits are systematically undertaken, the findings and action plans may provide enough evidence that inspectors do not need to look at individual records. Base your standards on the CGDent clinical examination and record-keeping guidance. CQC does not set a fixed frequency for this audit, so choose a cycle that suits your practice, record it in your audit schedule and repeat it after you make changes.
The audit cycle
Mythbuster 17 describes the cycle as:
Identify the audit topic.
Set the standard.
Collect the data.
Analyse the data against the standard.
Implement the change and share the results.
Re-audit to measure the effect.
A simple annual audit calendar helps. Put the two infection control audits six months apart, then add your radiography, accessibility, record-card and prescribing audits around them. Give each one an owner and a date for the re-audit.
Peer review and quality improvement
CQC says it considers peer review to be one of the hallmarks of a well-led practice. Mythbuster 17 also mentions the South Staffordshire Local Dental Committee peer review toolkit as one option. Quality improvement projects, where the team tests small changes and measures the result, are also welcome evidence. My post on writing a governance policy for a dental practice shows how audit fits into wider governance.
Common gaps I found
Infection control audits more than six months apart.
Radiography audits that only graded images and ignored justification.
No accessibility audit at all.
Action plans with no owner or date.
The same actions carried forward every cycle with nothing changing.
Free dental audit template
To help you get started, I have put together a free CQC Dental Radiography Audit Template in Excel. It takes you through a retrospective audit of 20 intra-oral radiographs per clinician, checking justification, image quality grading, reporting and repeats. The template uses a 95% target for digital images and builds in a six-monthly re-audit, so you can show the full cycle. There are fields for the practice, the auditor, their GDC number and the audit cycle, plus a guidance tab explaining how to complete it.
Download the free CQC Dental Radiography Audit Template (Excel) and use it for your next radiography audit.
Getting ready
If you want an outside view, my dental mock inspection includes a review of your audit programme. The dental mock inspection template is on my free CQC resources page, and my guide to preparing for a CQC dental inspection covers the rest of the visit. New practices can get help through my dental CQC registration support and registration application support.
Final thoughts
Clinical audit in dental practices is not about collecting forms for CQC. It is how you find problems before patients are affected and prove that you fixed them. Run the essential audits on time, act on what they show and re-audit. Do that and your audit file becomes some of the strongest evidence you can give an inspector.
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