Yesterday (16 September), CQC published a joint statement of Chief Inspections about the transitional inspection framework that is expected to run until next spring when the new inspection framework is due to launch.  Here are the key points, and the implications for providers.

Key points

  • Launches on 6 October 2020 for adult social care and dental services.
  • Initial focus on safety, access to services and leadership, but based on existing KLOEs.
  • Use of information for all available sources including from Provider Collaboration Reviews.
  • CQC promoting feedback using CQC’s ‘Give Feedback on Care Services’
  • On-site inspections limited to obtaining evidence that cannot be obtained by other means.
  • No return to inspections at fixed intervals.
  • Focus on providers where CQC has concerns.
  • If CQC is satisfied there is a low level of risk after conducting a desk top review of monitoring information, it will let providers know but this won’t change the rating. However, in time, CQC proposes including a short statement on the service’s page confirming the outcome.
  • If the review suggests a risk, CQC will inspect and review any or all KLOEs. However, as inspections will be targeted based on risk, not all KLOEs may be inspected meaning there will be fewer changes of ratings.

 

Implications

  • Services that are currently rated as Requires Improvement who have invested in improving quality are likely to be the big losers because the level of risk may now be too low to warrant an inspection, and so there may be long delays before the ratings are raised to Good.
  • Similarly, those services that have worked hard to raise standards to Outstanding are likely to be disappointed as it seems unlikely that CQC will inspect them soon.
  • Given that ratings are likely to be out of date in many cases, providers will need to consider novel ways of communicating improved quality to commissioners and prospective clients. Certainly the sector will need to educate commissioners that, frankly, dated ratings will not be a reliable indicator of quality.
  • If occupancy fails to recover due to an outdated rating, that should be raised with CQC as a matter that could ultimately threaten the viability of the service. CQC should be invited to inspect on that basis.
  • CQC will be leaning heavily on data from a variety of sources. It is vital for providers to identify and resolve concerns with stakeholders promptly to avoid falling into CQC’s sights.
  • If providers received positive feedback, they should signpost the CQC feedback feature (link above).
  • The sector will need to keep a close eye on whether elements of the system lead to unfairness. For example, will providers have access, and be given the opportunity to respond, to the information that CQC uses for its initial desktop review?  That information  will undoubtedly prime CQC’s view of the service, and consequently its final judgments (see my article on unconscious bias and CQC here).

The joint letter is available here. I will blog again when I receive CQC’s internal guidance.

 

If you need any help with CQC or any other healthcare regulatory matter, please get in touch:

Telephone: 0207 406 7532

Mobile: 07980 897 429

Email: jlandau@healthcarecounsel.co.uk

 

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