Lucy Bowker, Solicitor, and Neil Grant, Partner, Gordons Partnership Solicitors
The Care Quality Commission (‘CQC’) have been publicising their new regulatory approach but what does this mean for people working in the health and social care sector?
Fundamentally, it is important to remember that the law has not changed.
The regulations remain the same. The key questions remain the same. CQC will still be looking at whether a service is Safe, Effective, Caring, Responsive and Well-led.
It is the way in which CQC approach regulation which will change and not the fundamentals of compliance with the regulations. A Single Assessment Framework will apply to all registered services from the largest hospital to the smallest social care service.
Key Lines of Enquiry will be replaced with Quality Statements. These are a series of very broad ‘We statements’. The idea is that these statements show what is needed from everyone in order to “deliver high-quality, person-centred care.”.
Each statement falls under a key question and is linked to relevant regulations.
In practice, if you are compliant with and understand the regulations, the quality statements are unlikely to pose a problem for your service.
CQC have changed the way they approach evidence and have grouped evidence into six different categories as follows:
- People’s experience of health and care services – defined as “a person’s needs, expectations, lived experience and satisfaction with their care, support and treatment. This includes access to and transfers between services” – Examples of this type of evidence include feedback from relatives and people who use services.
- Feedback from staff and leaders – Examples include results from staff surveys, supervisions, interviews with leaders and whistleblowing.
- Feedback from partners – Evidence can be gathered through interviews and engagement events. Partners include commissioners and external health and social care professionals who deliver services to your clients.
- Observation – Inspections carried out on the premises by CQC Inspectors and Specialist Professional Advisors.
- Processes – CQC will consider evidence measuring outcomes from processes. For example, they will look at how a service has measured and responded to information from audits and how a service has looked at learning from incidents.
- Outcomes – CQC will consider things such as mortality rates, emergency admissions to hospital, infection control outcomes and vaccination data.
Changes to how quality is assessed
Evidence to support judgements will be gathered in a variety of ways and at different times with inspections supporting this.
When planning inspections, ratings will not be the key factor deciding whether to physically inspect a service. Any evidence can trigger an assessment.
Judgements about quality will be made more frequently, often without the need for an inspection visit. Scores for different evidence categories will be updated at different times and will be combined to get a percentage score for each quality statement. The scores will be broken down as follows:
- Over 80% = outstanding
- 63-87% = good
- 39-62% = requires improvement
- 25-38% = inadequate
Scores will initially only be shown to providers but CQC would like to publish scores more widely in the future.
CQC have committed to rolling out the Single Assessment Framework across the whole country by the end of March 2024. To start with they intend to trial it in the South of England, possibly as early as November 2023. It remains to be seen whether these timescales will be met.
It would be advisable to keep an eye out for these changes to the way CQC regulate. While it does not alter the law, it will alter what CQC engagement looks like for providers, managers and care workers. Staying on top of this will help you to present your service in the best light possible.