CQC has recently launched its final consultation – Shaping the Future – on its 2016 to 2021 strategy and business plan. The consultation follows the ‘Building on strong foundations’ consultation which closed for public comment on 22 November 2015. The consultation closes at noon on 14 March 2016 and responses will be used to develop CQC’s final strategy which is intended to be published and implemented from May 2016
CQC’s strategy is focused around 6 main themes:
- Improving its use of data and information
- Implementing a single shared view of quality
- Targeting and tailoring its inspection activity
- Developing a more flexible approach to registration
- Assessing how well hospitals use resources
- Developing methods to assess quality for populations and across local areas
The consultation is general in nature as one would expect and is not particularly revelatory. Most of the consultation commits CQC to doing things that it has a duty to deliver anyway, such as taking action to protect service users, encouraging improvement and ensuring providers use resources efficiently. However, the consultation does highlight one proposal that is potentially more significant to the sector: achieving a single shared view of quality.
A single shared view of quality
CQC sets out its aim for there to be a “single shared view of quality” across health and care services. CQC says that it will work with providers and oversight bodies in implementing this vision. In part, this commitment reflects CQC’s regulatory requirement under section 67 of the Health and Social Care Act 2008 to promote the effective co-ordination of reviews across agencies. Until now, CQC has not really delivered on this duty. In practice, there is considerable duplication within the system with local authority and NHS commissioners developing their own quality monitoring standards which add unnecessary burdens on providers, as well as often creating inconsistency and uncertainty in terms of what is expected of services. In part it was a lack of faith in the old CQC that led many commissioners to do their own thing around quality, but there is also a sense that commissioners see the private sector, when providing publicly funded care, as a mere extension of themselves. Commissioners will also argue that they apply standards under contract specifications in relation to individual service users that can go beyond the merely adequate. However that argument is less convincing when the CQC rating system looks beyond adequate, with good being the starting point.
The clear indication is that CQC expects regulatory bodies and providers to follow its quality framework when making their own judgements. As CQC states in the consultation:
“We would ultimately like to see all national and local oversight bodies (such as NHS Improvement, NHS England, commissioning groups, local authorities and professional regulators), as well as providers themselves, use this framework to understand and report on provider quality.”
As providers are well aware, the CQC framework covers the Fundamental Standards, the 5 key questions, the Key Lines of Enquiry and the rating characteristics, along with data and information sharing resources. It will be interesting to see how the plethora of oversight agencies respond to this aspiration of a single shared view of quality given the turf wars that exist within the system. Not infrequently, at Ridouts we come across real disagreements between CQC and commissioners regarding quality in particular services.
The consultation states that as far as providers are concerned, the use of the quality framework will enable them to “tell CQC more about how they are delivering high-quality care and where they are making improvements.” David Behan recently stated that CQC expects every NHS provider in England to remodel their data dashboards and governance agreements to fit with CQC’s framework. The same principle would apply to care providers in the social care sector. Indeed one would expect providers to want to adapt their quality assurance processes so that they are consistent with CQC requirements and many already do so.
One of the problems in the current system is that no-one oversees commissioners. The Audit Commission was disbanded and CQC has no duty to assess commissioners, unlike its predecessors. However, if CQC starts to regulate areas and population groups, not just individual services, it will need to consider the commissioning angle. In the longer term this might be the investigative route to promote a single “shared view of quality.” It is perverse that there exist such wide variations in quality monitoring frameworks and standards across commissioners. One can only hope that over the next few years CQC will tackle inconsistency in relation to quality rigorously both internally and across the statutory bodies it works with in order to fulfil its duty to promote the effective co-ordination of reviews across agencies in the interests of service users and the providers who care for them on a daily basis.