The CQC has set out proposals for a new factual accuracy process and has invited providers of health and social care providers to comment on suggested changes.
In August this year CQC asked for views on ways they can improve their factual accuracy process. In response to these views, which included making the process digital and more clear for providers, they have now created a list of proposals and asked for views on these by 31 October 2018.
The list of proposals are:-
- To develop specific provider guidance with clearer instructions and examples.
- To make our form simpler and mandatory (the only way we will accept provider information).
- To word limit each point that is being made on the form, but not the number of points.
- To ask submissions to identify where and how the information supports the point (rather than sending us lots of material).
- To stick strictly to the 10 days’ time limit for submissions.
- To allow discretion to the time limit but only in exceptional circumstances.
- To develop a digital solution (this is a longer term aim).
These proposals are quite alarming and are a clear attempt by the CQC to try to stifle the response that providers might make to an inaccurate report.
The proposals do not naturally fit with the findings from the August consultation and it would appear that the CQC is now taking the opportunity to make its own life easier by limiting what a provider can say about a draft report and discouraging providers from sending additional material. Making the process clearer for providers should not involve limiting their opportunity to provide detailed and thorough responses by way of word limits and making submissions on evidence to support their points.
In our view, this is a clear indication that the CQC is not equipped to deal with detailed submissions where their draft reports are inaccurate. The best solution would be to improve training of inspectors and share detailed and accurate inspection notes –both of which would promote transparency of findings. This positive action would, in itself, limit the need to challenge so robustly. Instead, the CQC have opted to manipulate its own system to reduce the scope of argument and deny providers the proper right to reply by limiting responses and addition conditions to what will and will not be considered.
We would urge providers to participate in the consultation which can be found at https://communities.cqc.org.uk/provider/document-for-review/tell-us-what-you-think-about-our-proposals-improve-factual-accuracy-process and let the CQC know your thoughts on its proposals. Ridouts will be submitting its own thoughts to the CQC to try to protect provider’s right to respond and ensure that they are not denied the basic natural justice of fully responding to inaccurate and misleading reports.