The CQC has recently published additional insight into its scoring process under the new inspection methodology, including explaining how ratings limiters will be applied in the future.
Under the current system of KLOEs, prompts and ratings characteristics existing CQC guidance for adult social care services outlines specific ratings limiters related to the Well-led rating. If the circumstances apply, the Well-led key question cannot be rated better than Requires Improvement. The relevant circumstances are:
- The location has a condition of registration that it must have a registered manager but it does not have one, and satisfactory steps haven’t been taken to recruit one within a reasonable timescale.
- The provider has any other condition of registration that is not being met without a good reason.
- Statutory notifications were not submitted in relation to relevant events at the location without good reason.
- The provider has not returned PIR information where requested by CQC, or has not suppled the information in another format, indicating that the service is unable to demonstrate an understanding of the importance of keeping and using management information to deliver a good, safe service.
In addition, the overall rating for a service cannot be better than Requires Improvement if there is a breach of regulations. The reasoning provided behind this additional limiter is because providers rated as Good are meeting the standards set out in the regulations and display the characteristics of good care. Furthermore, while not explicitly stated in CQC guidance, a key question is unlikely to achieve a rating higher than Requires Improvement if there are any regulatory breaches referenced within that section. Inspectors should apply their professional judgement in assessing whether findings are serious enough to warrant the assertion of a regulatory breach and whether any relevant ratings limiters should be applied.
It is unclear whether the same ratings limiters will be carried over into the new system. However, information published by the CQC in relation to the new approach to assessment confirms there are certain circumstances, linked to its assessment of the new quality statements and evidence categories, that would limit a rating.
The new assessment process refers to a new scoring system to be used when considering evidence under each quality statement. The scoring system assigns a score of 1-4 to each evidence category (1 indicating significant shortfalls and 4 indicating an exceptional standard). These scores are combined to give a quality statement score and these scores are subsequently built up to indicate ratings to be reached for each key question and ultimately an overall rating. The CQC has confirmed that whilst certain score ranges have been published to demonstrate the achievement of certain ratings, this can be deviated from if the following limiters apply.
If a key question score is within the:
- Good range, but there is a score of 1 for one or more quality statement scores, the rating is limited to Requires Improvement;
- Outstanding range, but there is a score of 1 or 2 for one or more quality statement scores, the rating is limited to Good.
In addition, CQC inspectors will continue to be able to apply their professional judgement if a quality statement score produced does not reflect the quality for any specific topic. The CQC states that by using the rules, it can make sure any areas of poor quality are not hidden.
The main message from the CQC is that all of the quality statements are treated equally and providers must ensure compliance across the board to avoid being stung by one of the ratings limiters. While published ratings limiters were previously only relevant to the Well-led key question (please see comment in relation to regulatory breaches above), limiters under the new system apply to all key questions equally.
The CQC intends to publish its full provider guidance later this month and is hosting another webinar at 9am on 20 September 2023, this time focused on the quality statements and evidence categories. Providers are encouraged to attend to help gain further insight into how their services will be assessed moving forwards.