CQC Infection Control Audits: What to Check and How to Evidence It

Infection prevention and control (IPC) has always been a core component of CQC inspections, but expectations increased sharply during and after the COVID-19 pandemic. The IPC-related quality statement S7 now carries significant weight, and CQC assessors arrive with a detailed understanding of what good IPC governance looks like.

For care home managers, the question is not whether to audit IPC — it is whether your audits are thorough enough to satisfy CQC and, more importantly, to keep your residents safe. This guide covers what to include, how often to audit, and what evidence to keep.

Why IPC audits matter more now

COVID-19 changed the regulatory landscape for IPC in care homes. Several developments increased expectations:

The Health and Social Care Act 2008: Code of Practice on the prevention and control of infections (the Hygiene Code) was updated, and CQC uses it as the benchmark for compliance with Regulation 12(2)(h).
UKHSA (UK Health Security Agency) replaced Public Health England and published updated IPC guidance for care homes, including respiratory infection management that goes beyond COVID-19.
CQC introduced targeted IPC inspections during the pandemic. While the specific targeted inspection programme ended, the inspection methodology it developed — including detailed environmental walkthroughs — has been absorbed into routine assessment.

The result: CQC assessors now expect a higher standard of IPC documentation, more frequent auditing, and demonstrable evidence that audit findings drive improvement.

What your IPC audit should cover

A comprehensive IPC audit in a care home should cover the following areas. Use this as a checklist framework and adapt it to your setting.

Hand hygiene

Hand hygiene facilities available at point of care (soap, water, paper towels, alcohol-based hand rub)
Hand hygiene technique audits (observed, using the WHO 5 moments framework)
Compliance rates tracked monthly with a target of 90%+ (document actual percentage)
Staff nail length and jewellery compliance (bare below the elbows)
Signage at wash stations
Hand cream available (dry, cracked skin is an infection risk)

Personal protective equipment (PPE)

Adequate stock levels of gloves, aprons, fluid-resistant surgical masks, eye protection
PPE stored correctly (clean, dry area, within expiry date)
Staff observed using PPE correctly (donning and doffing technique)
PPE waste disposed of correctly (clinical waste stream for contaminated items)
Evidence of fit testing for FFP3 masks where required (nursing homes performing aerosol-generating procedures)

Environmental cleanliness

Cleaning schedules in place for all areas (resident rooms, communal areas, bathrooms, kitchens, clinical rooms, laundry)
Enhanced cleaning protocols for outbreak situations documented and rehearsed
Cleaning products appropriate for the setting (evidence of using products that meet EN 14476 for virucidal activity where required)
Touch-point cleaning frequency (door handles, light switches, handrails, lift buttons — at least twice daily in communal areas)
Cleanliness audit scores tracked monthly, with photographic evidence where helpful
Mattress and soft furnishing integrity checks (damaged items are an infection reservoir)

Laundry management

Separation of clean and dirty laundry (no cross-contamination in corridors or storage)
Wash temperatures appropriate (65°C for 10 minutes or 71°C for 3 minutes per Department of Health guidance)
Handling of infected laundry (alginate bags or equivalent for items contaminated with body fluids)
Staff understanding of laundry IPC procedures

Clinical waste management

Correct segregation of clinical waste (orange bags for infectious waste, yellow for anatomical waste/sharps, tiger bags for offensive waste)
Sharps bins assembled correctly, not overfilled (fill line observed), and disposed of within 3 months of assembly
Waste storage area secure, clean, and compliant with Hazardous Waste Regulations 2005
Waste consignment notes retained for minimum 3 years (Duty of Care requirements)

Outbreak management

Written outbreak management plan covering norovirus, influenza, COVID-19, and scabies as minimum
Staff know how to declare an outbreak (2 or more linked cases within 48 hours)
Contact details for local Health Protection Team (HPT) accessible
Isolation procedures documented and practical (considering your building layout)
Visitor management during outbreaks
Post-outbreak debrief process documented

Resident-specific IPC

Catheter care plans where applicable (NICE QS90)
Wound care documented with aseptic technique where required
Antibiotic stewardship — evidence that antibiotics are prescribed appropriately (START SMART guidance)
Screening and assessment of residents admitted from hospital (MRSA, CPE screening per local ICB protocols)
Vaccination records for residents (influenza, COVID-19, pneumococcal)

Staff IPC

IPC training compliance — Level 1 for all staff, Level 2 for clinical staff and IPC leads, refreshed annually
Occupational health records for staff (hepatitis B status for clinical staff, immunisation status)
Fit-to-work assessments — policy on staff working when symptomatic
Staff vaccination uptake monitored (influenza, COVID-19)

How often to audit

CQC does not prescribe a specific IPC audit frequency, but the expectations below — based on inspection report patterns and the Hygiene Code — represent a reasonable baseline. Adjust for your service's risk profile, outbreak history, and commissioner requirements:

IPC audit element	Recommended frequency
Hand hygiene observation	Monthly
Environmental cleanliness	Monthly
PPE compliance observation	Monthly
Sharps and clinical waste	Monthly
Laundry	Quarterly
Mattress integrity check	Quarterly
Water systems (legionella)	Monthly temperature checks; full assessment annually
Outbreak preparedness review	Six-monthly
Full comprehensive IPC audit	Quarterly
Kitchen food hygiene	Per local authority schedule + monthly self-audit

During an outbreak, increase audit frequency to weekly for environmental cleanliness and PPE compliance.

Documenting your audit results

CQC assessors will ask to see not just the audit but the complete improvement cycle. For each audit round, document:

Date, time, and auditor name — vary the auditor where possible to avoid blind spots
Area audited — specific rooms, floors, or departments
Findings — what was compliant and what was not, with specific detail rather than generic statements
Score or RAG rating — consistent scoring allows trend tracking
Action plan — for every non-compliant finding, record what action is needed, who is responsible, and the deadline
Action completion — evidence that actions were completed (photos of remedial work, training records, purchase orders for replacement equipment)
Re-audit — follow-up audit to confirm the issue is resolved

Maintain a trend tracker showing IPC audit scores over at least 12 months. CQC assessors find this particularly useful — it shows whether your IPC performance is improving, stable, or declining.

Quality statement mapping

IPC evidence maps across several quality statements:

S7 (Infection prevention and control) — the primary statement. Your IPC audit programme, policies, training, and outbreak management all sit here.
S5 (Safe environments) — environmental cleanliness, laundry management, waste management, and legionella controls.
S1 (Learning culture) — evidence that you learn from outbreaks and IPC incidents. Post-outbreak debriefs and resulting policy changes demonstrate this.
E2 (Delivering evidence-based care) — that your IPC practices align with current UKHSA guidance and the Hygiene Code.
W5 (Governance) — that IPC audits feed into your governance framework, are reported to the provider, and drive improvement.

Common CQC findings on IPC

Published CQC inspection reports reveal recurring IPC issues:

"Cleaning schedules were in place but we found areas that had not been cleaned to an adequate standard." The schedule is not enough — the audit must check actual cleanliness, not just whether the schedule was signed.

"Staff were observed not following correct hand hygiene procedures." Observation-based audits are essential. If you only audit whether soap is available but never watch staff wash their hands, you are missing the point.

"There was no evidence that the provider had learned from a recent outbreak." After any outbreak, conduct a formal debrief within 2 weeks. Document what happened, what went well, what could improve, and what changes you are making. File this with your IPC audit records.

"Mattresses were stained and damaged, posing an infection risk." Mattress audits are often overlooked. Check under fitted sheets quarterly. Replace any mattress with a compromised waterproof cover.

"Sharps bins were overfilled." A simple compliance issue that creates a disproportionately negative impression during inspection.

The role of the IPC lead

Every care home should have a designated IPC lead. This is typically a senior carer or nurse who has completed Level 2 IPC training and takes responsibility for:

Coordinating the IPC audit programme
Maintaining IPC policies and updating them when guidance changes
Delivering or arranging IPC training for all staff
Acting as the point of contact during outbreaks
Reporting IPC performance to the registered manager and governance meetings

Document who your IPC lead is, their qualifications, and their responsibilities. CQC assessors will ask to speak with them.

Getting started

If your IPC audit programme needs strengthening, start with three actions:

Conduct a baseline comprehensive IPC audit using the checklist areas above. Score everything honestly. This gives you your starting point.
Set up a monthly audit cycle covering hand hygiene, environmental cleanliness, and PPE compliance — these are the three areas CQC scrutinises most during inspections.
Create an action tracker and review it at your monthly governance meeting.

For help structuring your audit programme, see our guide on building a care home audit schedule. For guidance on environmental and individual risk assessments that support your IPC programme, see our care home risk assessment guide. And for a complete overview of CQC requirements, see our CQC compliance guide for small care homes.