In 2021, the CQC unveiled its latest strategy for regulation including a new ‘single inspection framework’ which claims to ensure a greater emphasis on ‘care integration, people’s experiences, cultures of safety and learning/improvement.’ During the pandemic, routine inspections ceased all together and it seems the CQC has taken this opportunity to phase them out as the predominant form of evidence gathering. The ‘single inspection framework’ will introduce commissioning roles for Integrated Care Systems and local authorities to cover health and care providers. CQC’s ambition is to ‘drive improvement’ for service users as well as reduce health inequalities across the board.
Following its inception in 2021, the remainder of the new regulatory approach will be unveiled in stages, the next of which will be initiated in August 2022, before further expansions in September and October 2022. The goal is for the new regulatory strategy to be fully rolled out to all providers by the beginning of 2023. With the new strategy still operating in its developmental stage, what is the current approach we are witnessing on the part of the CQC?
The Current Approach
During the interim period on the road to the new strategy, the CQC has maintained post-pandemic focus on risk-based inspection. The Commission will inspect providers if concerns are raised in regards to safeguarding by means of complaints or whistle-blowers.
This risk-based approach to inspections may have led to inspectors failing to observe positives within a service as there has been a lack of providers who have seen their ratings improve. Services with no concerns have been left to wait a long time for an inspection. The CQC has even been slow to address services that are rated below ‘good’, but have improved and therefore would like a re-inspection. This means providers are stuck with a rating that they may not deserve because they have shown improvement but no longer demonstrate the risks that would prompt a re-inspection.
It also seems to be the case that the CQC is not making any considerations for the hardships and readjustments that providers encountered during the pandemic. Factors such as staff shortages, for example, have largely failed to be taken into account during inspections.
The current regulatory approach by the CQC has effected provider ratings up and down the country. Evidence suggests therefore that the CQC has been taking a heavy-handed approach in the early, transitory stages of the new strategy. But how will the forthcoming stages of the new regulatory strategy and the subsequent approach from the CQC effect providers in the road ahead?
The Road Ahead – New Inspection Framework
The CQC’s new ‘Single inspection framework’ promises to replace set-piece inspections with continuous, ‘multi-point’ assessments. This will largely be supported by a remote collection of information from providers. The CQC vow to make it clearer to providers about what evidence they require. Despite the apparent move towards remote forms of inspection, the Commission has asserted that on-site inspections remain an important part of evidence gathering.
Although the frequency of inspections will decrease, the CQC will prioritise inspections where there is evidence of potential poor culture; these inspections could be longer and more frequent. Providers at risk of having ‘poor culture’ will be identified using the internal CQC ‘dynamic dashboards’ which uses feedback from service users, care workers and partners. This will keep the Commission and provider up to date with continual information on the standard of care that the service is perceived to be providing. Services will be provided with even more information to highlight areas of improvement. A cause for concern on the dashboard may prompt an inspection.
The structure of reports are also to be changed with shorter, score based statements replacing the longer, descriptive reports. Score-based statements will compare the quality of provision against other equivalent providers. This will result in providers being less likely to be penalised for failing to meet any potential over-ambitious targets set by themselves. If a provider exceeds a comparable provider, they will not be criticised for failing to meet their own personal targets.
The CQC are going to keep the five key questions – Safe, Effective, Caring, Responsive, Well-Led, but they will be accompanied by ‘I Statements’ which describe, through the lens of a service-user, how they should experience care. The example the CQC give is:
- “When I move between services, there is a plan for what happens next.”
The 300+ lines of enquiry, which providers will be familiar with, will be replaced by 34 ‘quality statements’ which focus on how care is provided. Each quality statement will be rated from one to four and will be categorised underneath a key question. For example:
The CQC say that a complete reassessment is not required for a change in ratings.
Time frame for the rollout of the New Regulatory Strategy
The CQC has released its new regulatory strategy in phases because it says it wants to learn as it goes. The next phase of their new strategy will be rolled out in August. This is the forecast for the timeline which is expected to be ready for nationwide implementation in 2023:
- ‘Early Adopters’ or small groups of providers who are registering for the first time will have their applications assessed using the ‘single assessment framework.’
- Early adopters will use the new online registration process which operates within the new CQC portal.
- Expansion of the number of early adopters to include a ‘small number of GP practices, independent providers and care homes.’
- There will be a process for early adopters to make changes to registration including the ability to: add and remove partners, advise CQC of a cancellation, update a statement of purpose, add or remove a location.
- Aim to have the new provider portal available for all sectors by ‘the end of the calendar year.’
- All providers will be given access to the new provider portal.
- Start using the ‘New Assessment Approach’ with an early adopter group.
- Introduce a ‘more dynamic and flexible’ regulation with a change in the format of information which is provided to providers and the public. They vow this will lead to more ‘proportionate responses.’
- Move to the more continuous, multi-point assessments rather than routine inspections as discussed above. This will be based on a constant flow of evidence rather than a provider’s previous rating.
- A ‘full roll-out’ of the new way of regulating.
- All providers will: be using the new provider portal, start to have built relationships with the local CQC team and start to be regulated against the new single assessment framework.