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November

Winter is coming: CQC’s Game Changing Strategy  

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Will Marshall, Head of Legal & Risk Management

Winter is coming: CQC’s Game Changing Strategy  

How the CQC is planning to enable care providers in England to transcend organisational boundaries and develop a more unified healthcare ecosystem.

This winter, the Care Quality Commission (CQC), the independent regulator for health and social care in England, is ushering in a series of fundamental changes that promise to redefine healthcare regulation in the country. Since it published its new strategy for the changing world of health and social care in 2021, the CQC has been championing a brave new regulatory world that offers increased consistency, flexibility and transparency to its regulated providers and its service users.

In the first of our series of regular newsfeeds on this topic, we will be covering the introduction of the CQC’s forthcoming single assessment framework. In this article, we highlight what’s changing and how and when these changes will be rolled out across England.

Background to change

These changes will be achieved by the staged roll out of a new single assessment framework Our new approach to assessment - Care Quality Commission (cqc.org.uk), due to commence this November. The CQC is confident that, once in place, this new framework will be better equipped to meet the needs of an evolving and increasingly complex health and care environment that frequently features multi-provider and multi-sector care journeys.

At its heart, the new framework aims to enable the CQC and the 51,000 plus providers it currently regulates across England to better understand the quality of care provision within a particular organisation, and linking up across much wider systems, sectors and entire regions.

A new assessment framework

The single assessment framework will cover all providers, services and levels. The deployment of what is being described as a new and simplified approach to assessment will take place this November, starting with providers in the South of England, before being introduced sequentially to the other three regions (London & the East, the Midlands and the North) by the end of March next year.

The CQC has embarked on a lengthy publicity campaign to ensure providers are kept fully up to speed with the implementation process as it impacts them, including a webinar programme to run alongside the full provider guidance publications. The next webinar in the series is due to take place on 20 September and will focus on quality statements and evidence categories.

The intention is to give everyone at least 2-3 months’ notice of any major changes. In the interim, the CQC will continue to use its current methods to monitor, assess and rate providers.

What is changing?

Quality statements

The CQC is keen to emphasise that several familiar elements of its current assessment process will remain in place. The new framework will continue to use the five key questions (safe, effective, caring, responsive and well-led) and a four-point rating scale (outstanding, good, requires improvement and inadequate).

However, there will now be a set of quality statements (expressed as “we statements”) under each key question that focus on what good care looks like and that link to the applicable regulations. These quality statements intend to set clear expectations of providers based on people’s experiences and the standards of care they expect. They will replace the previous key lines of enquiry (KLOEs), prompts and rating characteristics and will be sector specific.

Evidence categories

The CQC is also introducing six new evidence categories to organise information under the statements. Each category sets out the types of evidence the CQC uses to understand the quality of care being delivered and the performance against each quality statement. The aim of this is to make the CQC’s judgements more transparent and consistent.

These new categories are:

· People’s experience of health and care services

· Feedback from staff and leaders

· Feedback from partners

· Observation

· Processes

· Outcomes

Inspections and assessments

The emphasis going forward will be on flexibility. The CQC will no longer use a service’s rating as the main driver when deciding when to assess, and inspections will no longer be limited to a single point in time. Instead, the focus will be much more proactive – with assessments based on various sources, including data and service-user complaints and feedback. This information will be used to target emerging service risks as well as responding to service failures.

Alongside this approach, the CQC will carry out ongoing monitoring of services to identify where it may need to take further action to ensure people are receiving safe care. The CQC believes that this change of approach will allow it to regulate in a more dynamic and flexible way, with more frequent engagement with providers and people who use their services.

To resource this change of approach, the CQC is creating new specialist teams based around the four geographic networks. It anticipates that there will be 110-115 teams, each led by an operations manager and made up of inspectors, assessors, regulatory co-ordinators and officers. All teams will be supported by a central hub for oversight and to capture data on a national level.

Ratings

The CQC still intends to describe the quality of care using the four ratings: outstanding, good, requires improvement or inadequate. However, a new scoring framework will be introduced to provide clarity and consistency. For example, for a rating of good, the score will clarify if this is either

in the upper threshold, nearing outstanding or in the lower threshold, nearer to requires improvement.

There will also be a move from the current lengthy and costly PDF inspection reports towards shorter, more accessible and streamlined judgements. Providers will be able to see their ratings and how they benchmark against other providers in their region. The intention is to move to more focused and concise reports that provide an up-to-date snap shot of the provider’s performance.

Provider engagement and the new portal

The CQC is piloting a new online portal to modernise how providers interact with it. Access to the portal will be incrementally rolled out over the winter.

The intention is that the portal will make it easier to share data with the CQC – including submitting notifications, registering or making changes to registration, and having access to the information held about their activity. The CQC hopes the portal will provide a more real-time view of how a service is performing – including information from other sources. It will replace the onerous Provider Information Return (PIR) document.

How we can help

With the implementation of the new single assessment framework, healthcare providers and service users can expect a more focused and nuanced approach from the CQC. This will look to provide an assessment of the quality of care provided by the individual service within a wider local, regional or national context. Quality of care will be benchmarked against similar sector providers with the aim of producing real-time data that will drive improvement and promote learning.

However, while this shift clearly has the potential to enhance patient experiences and outcomes, streamline resource allocation and promote collaboration among diverse healthcare stakeholders, there will inevitably be challenges along the way as the changes are embedded, not least the increased administrative burden – particularly for smaller services – as users adapt to the new system. The transition may involve significant investments in training and technology, which could divert resources away from direct patient care.

It is essential for all registered service providers that you are ready and prepared to meet these wide ranging changes, and that you know how and when they will affect you and your service users. To help our clients prepare for these key changes, and our brokers to support them, we will be publishing a series of regular updates, analysis and newsfeeds covering all key developments over the next few months. Our next article will focus on how quality statements and evidence categories will be used in the new, wider regulatory approach. Stay tuned.

“The information contained in this article does not represent a complete analysis of the topics presented and is provided for information purposes only. It is not intended as legal advice and no responsibility can be accepted by Altea Insurance for any reliance placed upon it. Legal advice should always be obtained before applying any information to particular circumstances.”

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