What’s staying the same?
CQC’s new assessment framework is still based on the five key questions and existing ratings of inadequate, requires improvement, good and outstanding. It still focuses on understanding the quality of care (including people’s experiences) in your service, and the type of evidence gathered by CQC will look and feel quite familiar. However, how CQC gathers evidence through ongoing assessments of the quality statements and on-site inspections will dramatically change.
What is the CQC’s new assessment framework?
CQC are moving from multiple assessment frameworks (Hospitals, Primary Medical Services, Adult Social Care, Registration) to a new single assessment framework approach for all health and social care services. What CQC look at in the new assessment framework will be broadly similar to their current approach, but how they assess services for quality and safety will feel very different.
Currently, inspections are scheduled by risk and previous ratings. Evidence is gathered through an inspection. Under the new model, CQC will have an ongoing approach to assessing quality and risk. This means they will collect evidence at multiple points (over two years) rather than just through an inspection.
CQC say the new model will support them to be more transparent and consistent in making judgments. They are developing a way to categorise and score evidence. The new provider platform will enable service providers to see how CQC have scored their service. In the future, CQC will publish information about a provider’s score, how this positions them within a specific rating and how they rate compared with similar services.
Inspection reports are currently lengthy documents which are not particularly accessible to people or families. In the future, your report will be much shorter and will provide an up-to-date view for the public because the assessments are ongoing.
The CQC’s new ‘Operations Group’ have four geographic networks: North, Midlands, London and East and South. The networks have individual CQC teams responsible for a geographical area, and staff will have different skills and experiences. Your relationship with CQC will change as they move from having individual inspectors responsible for a specific service to a relationship with your local team. More of your contact will be made via the provider portal, including seeking advice and guidance. CQC say you will find it easier and quicker to gain information or advice.
CQC are placing high trust in their new systems to identify risk or emerging concerns. We know that providers are concerned about the loss of individual relationships. We are also concerned about the risks of poor or unsafe services slipping through the net (the computer says ‘no’ scenario); however, we will need to see how the new systems work to protect people from harm, so watch this space.
One advantage of the new model is that CQC will view your specific service and see how your local area systems (hospitals, local authorities, GPs, voluntary and private providers) work in partnership to deliver joined-up safe, responsive and high-quality services. We think this is important.
We all know and experience the delays, scarce resources and confusing systems that can result in poor experiences for people. This includes the ever-wider cracks in the system that lead to poorer outcomes, duplicated work and conflicts as we all try to ensure people receive the right service at the right time.
CQC’s other new regulatory functions, including assessing local authorities, will also provide key information about how well a local system works for people. For the first time in over a decade, CQC will see how poor care at one end of the system has been influenced by poor systems, processes or decisions in another part of the system. For example, how local authority funding decisions for home care prevent services from delivering more than the bare essentials to a person. We will watch with interest whether CQC can use these insights to influence national policy decisions, social care funding etc.
When will the new CQC assessment approach be implemented?
Starting with providers based in South England, CQC is rolling out their new assessment framework to providers from November 2023. The rollout for other parts of the country will be phased between November 2023 and March 2024. CQC will tell you when you are moving to the new assessment framework, but until then, you will continue to be regulated under the old assessment framework. From April 24, the KLOEs and KLOE prompts will be retired, and all social care providers will be assessed under the model using the new quality statements.
CQC will use planned and responsive approaches to the initial phase of the new regulating methods. Planned approaches will include a minimum set of quality statements they will assess within a set time. Responsive approaches include responding to risk, for example, using the new framework to respond to information of concern, intelligence, notifications, etc.
CQC say they will not just be driven by risk but will take a proactive approach to assessing the quality of all services more frequently. They will be looking at how services improve and taking action where risks are identified. This is good news for service providers currently rated as requires improvement, where they can evidence they are providing a ‘good’ service in line with the quality statements. Historically, providers rated as requires improvement have waited a long time for their reassessment, despite having made all the improvements necessary to ensure they are providing good quality services. We hope the new CQC approach will focus on addressing the delays and issues these providers are experiencing.
The new provider portal
A new online provider portal will enable you to submit notifications, register, make changes to your registration, make factual accuracy responses and delegate access to the portal within your organisation. The portal will also enable you to access information about your service so that you can easily see how CQC makes judgements about you and how they benchmark your organisation relative to other similar providers.
CQC are testing the portal with 230 organisations through August and will start to invite other service providers from September. All providers will be using the new portal from March 2024. Invites will go to Nominated Individuals in the first instance. Ensure CQC has up-to-date contact details for your Nominated Individual as they will be the contact CQC email to which the portal joining invite is sent. You can check your organisation’s contact details at cqc.org.uk/change-contact-notification.
The provider portal will absorb the provider information return (PIR). CQC say they will try to obtain all information possible from other sources to simplify the PIR and make it less burdensome for providers.
How you can prepare
CQC have published the quality statements, evidence categories and their scoring approach. By the end of August, CQC say they will publish more information about:
- What initial quality statements CQC will look at, and over what period.
- The evidence looked at to assess each quality statement.
- How the assessment framework will be used for registration.
- How often CQC will assess providers.
- The transition to a ratings model underpinned by scoring.
Autumn Webinars from the CQC
CQC will be holding monthly webinars to support providers in understanding more about what the changes mean for them. Make sure you are signed up to the CQC adult social care bulletins to sign up to the webinars.
A note about transparency and consistency
This has been a long-standing issue for providers. The questions of:
- Can you be sure CQC’s judgement criteria are consistently applied across England? The answer from providers has been a resounding ‘no’!
- Does the judgement/rating applied to your service depend on the view of an individual inspector, the way one inspection team operates, or worrying variances across the country? The answer has been a resounding ‘yes’.
CQC have long sought to address these issues and say that a transparent approach to the quality statements, evidence categories and evidence gathered will demonstrate how CQC staff have reached their judgements and ratings.
The new internal systems and technology CQC introduces will enable them to see how judgements are made in an individual team, across a local area or wider network area or nationally. CQC will be able to see how similar judgements, based on similar types of evidence, are made, and they will be able to see when differences in the sort of decisions CQC make could result from an inconsistent approach to collecting, assessing or making judgements about evidence.
The proof will be in the pudding, as they say; CQC must get this right. It shouldn’t matter who inspects/assesses you, and it should be irrelevant whether you are based in Newcastle or Newquay!
Of course, only CQC themselves will be able to monitor themes and trends that would highlight consistency issues. CQC appears to be placing a great deal of reliance on the new model in preventing inconsistency and detecting risks to people, providing the main means of all communication and ensuring transparency between CQC and providers.
Let’s hope the ‘computer says ‘yes’, and CQC can finally become the effective regulator people using services and providers deserve.
Take Action
Want to learn more about CQC’s new assessment framework and begin to prepare for this significant and far-reaching change to how your service is regulated?
Join Duffy & Shaw for the CQC Regulatory Compliance and Best Practice webinar. Focused on helping you understand and prepare for these major changes, alongside other key areas of compliance, regulation and best practice, this webinar will start your preparation and build your knowledge and confidence. Whether it’s the quality statements, the evidence categories, how CQC will collect evidence or what you can do to prepare, join like-minded providers and compliance experts to stop worrying and start taking action.
References and Further Reading
Webinars – Duffy and Shaw Consultancy
CQC: The new single assessment framework
CQC: Provider webinar | Implementing our new assessment approach and provider portal – YouTube