CQC has recently launched its final consultation 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. In this article we review some key points highlighted in the new consultation.
CQC’s strategy is focused around 6 main themes. The consultation itself is not very revelatory in relation to CQC’s aims and many of these are based on areas that it has a duty to deliver anyway, such as taking action where necessary, encouraging improvement and using resources efficiently. However, the consultation hints at further changes that will be made to the inspection process and CQC’s general workings over the next 5 years.
Data and information gathering
One of the main themes is focused around CQC improving its use of data and information. The consultation states CQC is “aspiring to become intelligence driven”, however in the past this has never truly materialised. Various techniques have previously been adopted for the collection and analysis of data to better identify risks of poor care and all have been found lacking in certain respects. One of the latest attempts involved providers reporting on their own performance. Issues highlighted with this approach were the increased burden on providers to analyse data in a way that CQC required and the inevitable fact that some providers may be understandably anxious about highlighting a services potential weaknesses to the regulator.
The new strategy sees CQC investing in tools that will enhance its ability to interrogate large datasets and derive greater insight from information. The new model for the obtaining and analysis of information has been named ‘CQC Insight’ and is intended to build on CQC’s current intelligent monitoring systems. It is then hoped that this will guide CQC’s inspection activity going forward allowing it to prioritise its resources in response to identified risks. The effectiveness of this can only be revealed over time.
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. This 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. One of the intentions behind this is to reduce the regulatory burden on providers by ensuring all regulatory bodies work from a single agreed dataset for quality. This suggests that CQC expects regulatory bodies and providers to follow its guidelines on quality when making their own judgements. This would likely include the fundamental standards, the 5 key questions and the individual KLOEs applied to the services it regulates along with data and information sharing resources. Indeed, it was confirmed recently by David Behan that CQC expects every NHS Trust in England to remodel their data dashboards and governance agreements to fit with CQC’s framework. It is recognised that this view cannot be developed overnight and it will be interesting to see how the different regulatory agencies, for example commissioners and safeguarding teams, fit into this given their potentially conflicting objectives.
Assessing the use of resources
Another important change for NHS acute trusts is the introduction of CQC’s new responsibility for assessing how well hospitals use their resources (which is expected to be piloted from April to June 2016 with a full roll out planned in early 2017). This will include CQC checking that hospitals are making decisions in the most economical and efficient way with reference to their resources, ensuring services are sustainable and offer value for money. It intends to rate trusts in relation to their use of resources. CQC confirms its focus will be on how operational performance is structured and delivered to support economical and efficient care, rather than on financial management and controls, or on the financial position in isolation. Some have questioned whether this is necessary given the existing roles of Monitor and the NHS Trust Development Authority (which from April will be known as NHS Improvement) and who would be best placed to carry out this function. This is touched upon in the consultation but CQC confirms that it will be consulting separately on this later on in the year. The approach is intended to be applied to NHS acute trusts in the first instance and CQC then intends to extend this to all mental and community health trusts in 2017/18.
It is apparent from the consultation document that, whilst CQC has these ambitions for change and improvement, it continues to play catch-up with the goals from its previous 5 year plan. Year 1 of the new plan (2016/17) is mainly focused on completing CQC’s aim to have carried out a comprehensive inspection for all registered services. The initial aim was to have this completed by April 2016, but over time the goal posts have been pushed back.
Following completion of the comprehensive inspection regime, CQC then intends to shift to a more risk based regulatory regime. This may mean that those services rated as ‘Good’ or ‘Outstanding’ will see less frequent inspections and those rated as ‘Inadequate’ will potentially experience an increased frequency of inspections. It is also likely that future inspections will be focused on particular areas of concern and we will see a shift away from full, comprehensive inspections for services with ‘Inadequate’ ratings. It is unclear how frequently those services rated as ‘Requires Improvement’ will be inspected following this risk-based approach. Currently providers have to wait approximately 12 months before a comprehensive re-inspection. This is a long time to continue to have a ‘Requires Improvement’ rating if improvements have been made swiftly. Therefore we would hope to see these providers also seeing CQC coming back in more frequently to recognise improvements in care. The new approach could be very good for the sector if the frequency of inspections is used to drive improvement in areas where increased risks are apparent.
CQC itself accepts that the strategy both seeks to improve on what is currently being done as well as gradually introducing new ways of working. CQC also accepts that the underlying processes it uses, such as reporting and evidence collection, require improvement.
In the shadow of all of these goals is the fact that CQC is taking on more responsibility with fewer resources. The Government has asked the Department of Health for an overall reduction in spending of 25%. For CQC this is expected to mean that their budget of £249 million in 2015/16 will reduce to £217million in 2019/20. On the whole it is considered that CQC is responding positively to its reduced budgetary allowances, although there is an issue as to how much of the shortfall will be passed on to providers in terms of fees. However, how this is translated into effective practice is yet to be seen.
The consultation closes on 14 March 2016 and responses to the consultation will be used to develop CQC’s final strategy which is intended to be published and implemented from May 2016.