CQC Consultation Response – A Team Effort

The Care Quality Commission (“CQC”) launched their new strategy on 27 May 2021, following consultation with those who make up the sector. Some of the proposed changes have been a direct result of the change in working and regulatory practices following Covid-19, whilst others have been implemented to ensure the social care sector takes advantage of data and technology in an increasingly digital age.

CQC have identified four key themes and ambitions that will be central to the way they interact and regulate the sector.

  • People and Communities – CQC’s new strategy emphasises the importance of facilitating feedback from people using services, their families and advocates, although it is silent on how it will capture this wider range of feedback.
  • Smarter regulation – due to the constraints on CQC’s ability to physically inspect services during the pandemic, it has had to rely increasingly on a more data focussed approach to regulation. Providers will be asked to share high quality information with CQC on an ongoing basis to give a clearer indication of how that provider is performing. It is hoped that this will mean ratings will give a clearer real time indication of the quality of care, rather than relying on an inspection which typically only happens every few years. However further detail is required to determine how this will work in practice as it is not clear in what circumstances CQC might change a rating without carrying out a physical inspection.
  • Safety through learning – CQC wants to develop stronger safety cultures through learning and improvement across services, with an increased focus on openness and transparency when identifying, and addressing, shortfalls.
  • Accelerating improvement – CQC wants to encourage local support across services to facilitate and sustain improvement in social care services. CQC will encourage the collaboration of local services and systems with a view to facilitating innovation and improvement, so the local need is better serviced.

Running through each of these four themes are two core ambitions: assessing local systems in terms of the quality of care and tackling inequalities.

In terms of CQC’s year one priorities, it will be developing a new assessment framework which will see a revision to the current Key Lines of Enquiry and ratings characteristics, and the creation of a new provider portal which will be mobile friendly. CQC will also look to give a clearer definition of what “Good” quality care looks like and how that will translate to the culture of safe care provision.

CQC will also be working with partners such as NHSX to implement smart regulation at a local level so that useful data can be collected without it becoming a burdensome exercise on services and local systems generally. Whether CQC can make a real time system of regulation no more burdensome than the current framework is open to question. Much will turn on the ability of the various statutory agencies to share information freely and intelligently. It happens in the NHS but there is a way to go in social care.

The CQC strategy is light on detail, and it remains to be seen how it develops in a practical sense over the next 12 months and beyond. While CQC stresses the importance of collaborative working with providers, with a focus on improvement, CQC reminds us that it retains its core regulatory role which is to use its powers to act where it sees poor care, taking swifter action when needed. The key take away is that CQC is committed to pursuing a more risk-based model of regulation and as a result we can expect more, not less, enforcement action in the years to come.

The above article has been published in the June newsletter for Care Home Management, as well as this week’s Caring UK Weekly.