August 15, 2022
Article
It now appears that for most providers, the CQC’s new approach will be finalised and its new inspection framework will appear in January 2023. Carl May-Smith, partner and barrister at Browne Jacobson, outlines what it is likely to look like.
The CQC is developing a new inspection framework targeting implementation in January 2023, following on from various trials with early adopters which began recently (August 2022).
What is being prepared is a single inspection framework covering heath and care providers and the integration and commissioning roles of Integrated Care Systems and local authorities. The CQC are being given new powers to assess the latter two categories of organisation, and it is hoped that this may address previous provider concerns that they were punished by the CQC for issues that, in fact, arose from commissioning errors or inadequacies.
Point-in-time ratings stemming from set-piece inspections are to be replaced by ongoing multi-point assessments, delivering on the aim for more responsive service ratings. As a result, ratings may change much more often.
Additional sources of information will be utilised, particularly in relation to feedback from people experiencing care, care workers and partners in care pathways. Internal CQC ‘dynamic dashboards’ will inform regulatory action. More detailed, easier-to-digest information will be made available to the public, and even more given to providers to allow them to prioritise areas for improvement.
Long narrative inspection reports are to be replaced with scores, short statements and benchmarking of provision and outcomes against other comparable providers. The latter, if implemented well, could be one of the most significant positive impacts of these reforms; with ambitious providers no longer being criticised for failing to meet their own ambitious targets despite matching or exceeding the levels achieved by their competitors.
The five key CQC questions, Safe, Effective, Caring, Responsive and Well-Led, will remain but will now be complemented by ‘I statements’ describing how people should experience care, such as “When I move between services, there is a plan for what happens next.”
Below that, the current 300+ ‘Key Lines of Enquiry’ will be replaced by 34 ‘Quality Statements’ focusing on how care is provided. Each Statement will sit under a Key Question and be scored from one to four. The aggregate scores will determine the rating for that Key Question. In this way ratings can be changed without reassessment of the service as a whole. Where the CQC receives information relating to one or a small number of Quality Statements, it can update those scores and then reassess the aggregate and therefore the rating.
As well as the feedback describes above, observation of care (or inspection) will remain an important part of assessing most services. However, processes, policies and procedures will no longer be assessed on-site, but through remote collection of information from providers. Outcomes will also be given a much greater emphasis under the new framework.
If you want to get some insight into how this framework has been developed, visit www.thinklocalactpersonal.org.uk/makingitreal. The CQC has itself stated that it has borrowed heavily from this approach, to ensure that the framework does all it can to promote personalisation.
Choice, control and personalisation are said to be a golden thread throughout the new approach, with closed cultures remaining a key focus. This is alongside greater emphasis on safety culture, learning & improvement, listening to people’s voices, workforce wellbeing, equity of access, experience & outcomes and sustainability of services and the environment.
Overall, I am enthused by the CQC’s ambition. It offers a clearer way for providers to see how their rating is reached and can be improved. There will be greater transparency for the public. Benchmarking and dynamic re-rating offer real rewards for high quality and improving services.
As ever the key will be implementation. If my descriptions of how feedback will be collected, what data will be compiled and how or how benchmarking will work seem vague, that is because there is much to come in the detail of this approach. However, for now, I remain positive.
Carl May-Smith can be contacted at carl.may-smith@brownejacobson.com, telephone 0115 934 2024. https://www.brownejacobson.com