At Ridouts Professional Services Ltd, we are finding that sustainability of improvements is the major preoccupation for CQC on reinspection of services. That focus is only going to grow in importance given the terms of CQC’s Strategy for 2016-21 which it has recently consulted on. The proposed changes to CQC’s inspection methodology, which are due to come into force in October 2017 in relation to adult social care, are not about raising the bar, they are more about refining the current assessment framework following CQC’s completion of all its comprehensive inspections of adult social care services nationally since October 2014. As readers will know, there are Four Priorities which are the core of CQC’s strategy:
- Encourage improvement, innovation and sustainability in care;
- Deliver an intelligence-driven approach to regulation;
- Promote a single shared view of quality across England; and
- Improve its efficiency and effectiveness.
CQC is proposing to sharpen its focus on sustainability with a new Key Line of Enquiry (W4) under the Well-led Key question asking, “How does the service continuously improve and ensure sustainability.” The concept of sustainability involves an analysis of past, present and anticipated future performance.CQC looks for a track record of compliance and consistency of practice over time to reach a view on sustainability in rating services. The proposed “good” rating characteristics for the W4 KLOE are ones that all providers and managers should pay particular regard to, namely: “The service defines quality from the perspective of the people using it. Managers are knowledgeable about quality issues and priorities, understand the challenges, and take action to address them. Quality assurance arrangements are robust and identify current and potential concerns and areas for improvement. There is a strong focus on continuous learning at all levels of the organisation. Staff have objectives focused on improvement and learning. Leaders, managers and staff consider information about the service’s performance and how it can be used to make improvements. Performance information is used to hold staff to account. Concerns are investigated in a sensitive and confidential way, and lessons are shared and acted on. The service measures and reviews the delivery of care against good practice guidance. Leaders and managers ensure that good practice is shared and acted on throughout the service.” One particular concern we have at Ridouts is that CQC inspectors can sometimes focus on individual errors on the part of staff as evidence of breaches of the Fundamental Standards and that if the provider has not spotted them, it shows the quality assurance processes are somehow deficient. That is not the correct approach. One cannot legislate for human behaviour and errors will occur. Equally auditing by its very nature will involve sampling, with an annual schedule of audits in place. As a systems regulator, CQC should be balanced and proportionate in its findings. Isolated errors will occur in any care service but the key issue is whether the provider has robust quality assurance processes in place to minimise risks and act on issues that are identified. At the end of the day, the provider and registered manager need to demonstrate that they have taken all reasonable steps and exercised due diligence to achieve compliance i.e. there is an effective quality assurance regime in place and that issues are acted on. The key is to be able to demonstrate to CQC that is the case both on inspection and in relation to regular communication/updates sent to the regulator.