Legal

How providers and their staff can influence CQC to be more consistent

Caroline Barker, Director, Solicitor, Ridouts Professional Services Plc

CQC presented its draft Business Plan for 2019/2020 at its April Board meeting.  At the core of the plan are four key items, described as CQC’s purpose:

  • encourage improvement, innovation and sustainability in care;
  • deliver an intelligence driven approach to regulation;
  • promote a single shared view of quality;
  • improve their efficiencies and effectiveness.

One of the biggest concerns for Providers, is that the outcome of an inspection often appears to depend on the whim of a particular inspector on any given inspection day.  There can often be little consistency, not only between inspectors and regions, but also inspectors themselves –all of a sudden something isn’t good enough despite the same inspector having visited the home several times before and never raising the matter as a concern before.

Ensuring that CQC is consistent in its regulation is a key feature in its Business Plan but it is unclear how a single shared view of quality sits alongside encouraging innovation within care – not all care looks the same and a single shared view can shift quickly especially in an age where technology is developing rapidly and expectations can change.  It is important that providers and their staff don’t see an inspection as a non-participatory test, that only at the end, do you find out whether you’ve passed or failed, but rather see it an opportunity to educate CQC in how you care for service users and why you do it the way you do it.

CQC wants to “lighten the load” for its inspectors.  You may already have noticed the simpler, shorter form inspection reports being issued.  This is part of CQC’s desire to improve its own productivity and it has seen a reduction in the number of inspection preparation days which has resulted in an increase in the number of inspections carried out.  This, coupled with CQC’s desire to publish inspection reports more quickly, is another reason why it is so key that providers and staff engage with CQC on inspection days to actively promote the positive aspects of the service, rather than hoping that CQC will notice.  We all know that whilst inspectors are supposed to enter a service looking for ‘Good’ they often do the opposite.

CQC says it wants to “build strong relationships with providers to enable more regular updates on their delivery of care and plans, to support CQC’s regulatory planning.”  With less inspection preparation time and a desire for more formulaic inspection reports to be published as soon as possible, it would appear that CQC may be seeing inspections as a rubber-stamping exercise of what is exchanged in-between visits.

Providing information to CQC between inspections could be a double-edged sword – this could lead to an increase in inspections or enforcement action supported by evidence supplied by the provider.  A position difficult to counter.  However, it could also be an opportunity to demonstrate positive care initiatives.

Providers and staff need to be pro-active in their interactions with CQC, regardless of how those interactions manifest themselves.  There is no need for providers and staff to leave their rating to chance – it is your opportunity to inform CQC of what ‘Good’ care looks like and influence consistent behaviour and ratings which is so sorely missing at present.

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