CQC single assessment framework update

In May I wrote an update in relation to the new CQC single assessment framework that was finally rolled out (for healthcare providers and local authorities) in March of this year. We were aware that there was a proposed review being undertaken of the CQC which had already put on hold the inspections of ICBs. This was because the government (at that time) had declined to sign off on the proposed inspection regime due to concerns about the methodology being used.   

That process had been due to commence in April. The scrutiny of ministers was welcomed by many providers as there has been growing discomfort in the way in which the CQC inspection process has been carried out over the past few years, with little opportunity for realistic challenge. In particular low level challenges in relation to reports and ratings are time consuming and very limited in scope in terms of what they can achieve. A good example is the consistently high number of applications for ratings reviews that fail, purely based on the fact that on triage, the applications fail to meet the CQC’s stringent criteria. Providers need inspections carried out by people who have a deep understanding of their services, understand the challenges they face and recognise and report excellent practice. There has been inconsistency in approach for many years and such infrequent inspections that improvements go unreported and ratings remain unchanged. 

Care providers generally initially at least, welcomed the proposed new single assessment framework.  However, there have been concerns that the “review” of care has been insufficient and that too much reliance has been based on historic information so that improvements are not recognised and the reliable information in relation to services is not available for the public to access. 

It seems that the CQC is having its own difficulties not only in implementing the new framework but in being fundamentally competent to carry out its function.

On 15 July, the CQC published a statement from Kate Terroni the Interim Chief Executive of the CQC who had stepped in to temporarily replace the outgoing  Ian Trenholm. That statement started with an apology.  Ms Terroni said “We’ve got things wrong in the implementation of our new regulatory approach”  and reflected that they “had not delivered on their promises and made things more difficult for providers”.

She went on to confirm that the CQC had identified urgent and immediate areas of action by promising to:

• Increase and improve the support and guidance for providers on our regulatory approach
• Increase the number of assessments and inspections we are doing and to share more detail about that soon
• Work to get outstanding registration applications dealt with as soon as possible
• Work with providers to improve the portal and
• Test a new approach to relationship management that enables a closer and more consistent contact point for providers

It is perhaps the final promise that will be the most important for regulated service providers.  Over the years, there has been a theme of services losing their personal connection with inspectors and a move from a collaborative approach to regulation to a more draconian one. 

Today the interim findings of the review led by Dr Penny Dash were pretty damning of the CQC’s operational effectiveness reflecting that inspection levels were well below where they were pre-covid, there was a lack of clinical expertise among inspectors, a lack of consistent in assessments and problems with the IT system. The report states that these failings mean that the regulator is currently unable to consistently and effectively judge the quality of health and care services including those in need of urgent improvement. In other words, it is not fit for purpose.

The government has pledged to take immediate steps to restore public confidence in the effectiveness of health and social care regulation, including by increasing the level of oversight of the CQC, ahead of the full report awaited from Dr Dash which will be published in the autumn.

Professor Martin Green OBE, Chief Executive of Care England, has responded to the interim report by saying that “it is clear that Dr Dash has listened to the voices of care providers, resulting in a clear set of recommendations and that there is going to be a long and difficult journey for the CQC but one that is entirely necessary”.

Today, Ms Terroni has acknowledged the findings and recommendations of the interim report and said that the CQC accepts them in full and reiterated the promises made on 15 July.  She also confirmed the strengthening of the senior level healthcare expertise by the appointment of Professor Sir Mike Richards to conduct a targeted review of how the single assessment framework is currently working for NHS trusts and where the CQC can make improvements.

This oversight is welcomed by those providers who are keen to ensure that what is in the public domain properly reflects the expertise of their services to give service users and their loved ones the peace of mind and assurance they seek.