The Care Quality Commission’s New Inspection and Regulation Regime

The Care Quality Commission (CQC) has implemented a new inspection and regulation regime which is pegged to enhance the regulation of health and social care services. This blog will detail the key changes, their rationale, practical applications, and any early signs of difficulties.

 

 

Key Changes and their Rationale

1. A Single Assessment Framework (SAF)

Before the new SAF, the CQC used different methods to assess health and social care services, with separate frameworks for hospitals, adult social care, and primary medical services. The new SAF combines these into a single, unified approach, ensuring that all services are evaluated by the same standards.

2. CQC Quality Statements and Topic Areas

The CQC has updated its assessment approach by replacing Key Lines of Enquiry, prompts, and ratings with a new SAF that uses 'Quality Statements.' New topics and quality statements are expressed as 'we statements' to clarify what's needed for high-quality, person-centred care. The SAF also introduces new evidence categories, such as service user experiences with health and care services, feedback from staff, leaders, and partners, observations, and outcomes. The CQC hopes that this broader approach will give a clearer and more detailed view of service quality.

3. Changes to Inspections

While inspections will remain a crucial element of CQC processes, the new regulatory model

moves away from fixed schedules. Instead the CQC now employs a rolling assessment model based on real-time risk assessments and performance data. This approach aims to provide more timely insights into service quality and responsiveness to emerging risks.

4. A Reformed Scoring System

The CQC will continue using its four-tiered rating system to assess care quality (‘Outstanding, Good, Requires improvement, or Inadequate’). This method integrates existing data with assessments conducted both on and off site to provide a comprehensive view of quality. The CQC has plans to publish scores for greater transparency in the near future.

5. Better turnaround time

The CQC has recognised that providers often face long waits for their inspection results. To address this, they are streamlining and speeding up their reporting processes to deliver quicker turnaround times. By condensing reports and updating assessment methods, their goal is to provide a more up-to-date assessment of a service's quality and safety. These reports will now include detailed information, such as evidence scores and comparisons with similar providers across the country.

The CQC’s aim in making these changes is to create a more efficient, transparent, and outcome-focused assessment process that better supports the delivery of high-quality care. The primary objective is to assess not just how well providers adhere to rules, but also how their services genuinely impact the lives of service users.

 

practical application

The practical application of the SAF involves several key aspects.

1. Care providers will undergo structured assessments centred on the 5 Key Questions and corresponding Quality Statements. For example, assessments of effectiveness could involve reviewing patient outcomes and the implementation of evidence-based practices, such as emergency response procedures.
2. The CQC will conduct ongoing assessments driven by real-time risk evaluations and performance data. In practical terms, this means, the CQC will promptly investigate and adjust assessments to address the emerging risks i.e. patient safety concerns
3. As providers are required to integrate the newly defined Quality Statements into their operations, this might involve revising care plans to ensure they reflect individual preferences and needs, or enhancing staff training programs to align with the new values promoted by the SAF.

 

early challenges

The adoption of the SAF has presented several challenges for healthcare providers, with many facing significant adjustment to new Quality Statements and evidence categories.  

One major challenge has been technical problems with the provider portal, which providers use to submit evidence and communicate with the CQC. These issues have slowed down the process, making it difficult for providers to meet deadlines and interact effectively. On 11/ 12 March the, CQC acknowledged technical difficulties with the provider portal, but most of these issues have now been resolved. The portal should now be accessible to most registered managers, nominated individuals, and partners involved in CQC registration. While these glitches may occur again, the CQC is committed to addressing them quickly. This situation highlights the ongoing risk that comes with digitalising regulatory processes.

Another major concern for providers is the large number of Quality Statements in the SAF. These statements set care standards, but many providers find them overwhelming and unclear. The CQC is working to simplify these statements and provide clearer guidance based on feedback from providers, making it easier for them to understand and comply with the requirements. However, there are worries that the CQC is not assessing all the Quality Statements. The few reports released under the new framework show that only a few statements have been evaluated, with most ratings based on old information. This goes against the goal of the new system, which is to provide up-to-date ratings. While it's reasonable to give the CQC some flexibility as they roll out the new system, if this approach continues, it could damage the credibility of both the SAF and the CQC.

Furthermore, providers have raised significant concerns regarding the usability of the guidance section on the CQC website, describing it as confusing and challenging to navigate. In response, the CQC has taken steps to address these issues by providing clarity on guidance. In addition, the CQC has introduced 'last significant update' dates for guidance sections. This addition allows providers to stay informed about the latest changes and updates in regulations. These efforts reflect the CQC's commitment to ensuring clarity, accessibility, and transparency in its guidance and regulatory processes, thereby supporting providers in meeting regulatory standards effectively.

 

Conclusion

As of today’s, date (25 June 2024), the CQC’s Chief Executive has announced he is to step down at the end of the month. Given the changes have been driven during his tenure and are not yet embedded, it begs the question as to how the SAF will develop. The success of the SAF lies in addressing current challenges and ensuring assessments are conducted with transparency, accuracy, and fairness. The CQC has already expressed that it wants to learn from the feedback it receives from providers about the SAF, and will review how it is working towards the end of this month – providers will no doubt be keenly awaiting the upshot of the feedback.

further information

If you have any questions regarding this blog, please contact Shannett Thompson or Manvir Grewal in our Regulatory team.

 

about the authors

Shan is a Partner in the Regulatory Team and is the firm’s Training Principal. She trained in the NHS and commenced her career exclusively defending doctors. She provides regulatory advice predominantly in the health and social care and education sectors.

Manvir is a trainee solicitor at Kingsley Napley. She is currently in her second seat, with the Regulatory team. Her first seat was in the Real Estate team.