Amina Uddin takes a look at the Care Quality Commission’s proposed new phase of regulation, which closes to consultation on 14 February
The Care Quality Commission’s next phase of regulation aims to promote a more targeted, responsive and collaborative approach in its registration, monitoring and evaluation of health and social care services.
The consultation gives an early implementation date of April 2017. Sitting behind all of the proposed changes is the reality of the CQC operating within a smaller budget with a reduced headcount.
The CQC has acknowledged that for trusts, having to provide information such as policies and audits for every inspection is burdensome on their resources. It is envisaged that shifting the emphasis to strengthening ongoing monitoring and relationship management and conducting targeted inspections will reduce this burden.
Single shared view of quality
A theme which has been highlighted through the consultations in 2016-17 is the concept of having a single shared view of quality. The CQC believes that managing relationships with key partners such as NHS Improvement, NHS England and Healthwatch will help achieve a single shared view of quality. The rationale behind working with these key partners is to ensure that the CQC’s approach is exercised collaboratively to avoid duplication and to enable a platform whereby information is shared in a more manageable way to minimise requirements and information requests on trusts.
Provider Information Return
The current PIR request is lengthy and detailed, requiring arduous reporting requirements on trusts. The new PIR format will not be as detailed as its predecessor and promises to be more streamlined, only requiring trusts to provide the report on an annual basis.
The new PIR will enable providers to set out their views of the quality of care they provide against the five key questions. The CQC also expects trusts to provide information about any changes in quality since their last inspection. The PIR will not request information that is readily available from other sources.
There is an obvious risk in moving back to a system of self-certification given previous scandals, most notably Mid Staffordshire. The CQC will say it is different now with their data driven monitoring – CQC Insight – but only time will tell.
The CQC aims to move all information requests to a single online collection mechanism. Providers will use this to submit and update information. Moving to an online system will hopefully ensure that the information sharing process is efficient and accessible.
The CQC proposes to have a more targeted and tailored approach to inspection, focusing on core services and leadership. Regular inspections will be carried out to include at least one core service which will be assessed against the five key questions, approximately on an annual basis.
The CQC will look at previous inspection findings and ratings among other information to determine which core service needs to be inspected. Previous ratings of trusts will be used as a guide to setting intervals for re-inspecting core services. Re-inspection will likely occur within a year of the publication of the inspection report highlighting any inadequate ratings, two years for any requires improvement ratings, three and a half years for any ratings of good and five years for any ratings of outstanding.
Reports will be shorter and will be published more swiftly than is currently the case. Indeed, delays in publishing reports have been an abiding criticism of the CQC since its inception back in 2009. Reports will highlight which ratings are new and which are old ones. The concern, however, is how a trust’s overall location trust ratings will be changed if only targeted inspections take place.
Comprehensive inspections will now only be conducted when services are newly registered or where the CQC has significant concerns about a particular service. Only information that supports the CQC’s monitoring, inspection and rating of services will be requested from trusts.
CQC inspections have highlighted that effective leadership is an important driver for improvement in terms of delivering safe and high quality care. As a result of this observation, the CQC has proposed to carry out assessments focusing on overall leadership of trusts.
The assessments will include information such as how trusts assure themselves that systems and processes underpinning safe and effective care are implemented.
However, the move away from inspecting all core services will mean that decisions about the quality and effectiveness of leadership and management will be based on more limited inspection generated information. There is thus a risk that the evaluation of leadership will become more subjective and general in nature.
The Way Forward
Following the consultation, the CQC will roll out their new phase of inspection of trusts over the span of two years to ensure that there is sufficient time to evaluate and refine it. The new approach will be fully embedded by April 2019, and at that point in time, all trusts should have had a well-led inspection and at least one core service inspection.
Responses to the consultation must be received by 14 February. Further information including how to respond to the paper is available on the CQC website.
Amina Uddin is a solicitor for Ridouts Professional Services