The process for establishing the new regulatory framework by the Care Quality Commission (CQC) will move a significant step forward this month. At this time the pilot schemes come to an end and the regulator will evaluate the impact of its proposed changes. Charlotte Rowe, Care Practice Manager at Markel Care Practitioners, discusses the stages and wider implications.
With the expectation that the CQC will deliver its more substantive framework by the end of the first half of 2023, there is still a great deal of uncertainty but the aims behind the changes and the structure of the future framework are now evident.
While some areas will challenge providers, a number of positives will be delivered under the new framework, with renewed flexibility within the inspection process one of the most significant.
A changing CQC inspection process
The first question providers were asking when the plans were announced was how the CQC inspection process would be affected.
Previously, the CQC assessed care services solely via onsite inspection, gathering all the evidence through visits alone. Under the new model, the commission is moving to a broader, continuous approach by collecting evidence on an ongoing basis.
Routine inspections will remain key, but other methods will now assume real importance to the final outcome including submissions from providers and conversations with managers.
Inspectors will look to incorporate people’s experiences and obtain more detailed feedback from staff and leaders. They will include observations of care, and the outcomes of care set against evidence of process. In addition, they will seek feedback from partners.
The CQC will now be able to update a service’s rating at any time without onsite inspection in order to better respond to risk.
The frequency of care inspections was previously based on a provider’s most recent rating (with some ongoing monitoring), a system which troubled providers with many feeling it was difficult to improve their rating.
That looks to be addressed in the new framework. The new continuous approach increases flexibility and frequency, enabling commissioners and stakeholders to be presented with a more accurate assessment quality of care provided. Reports will also be shorter and score-based, making outcomes easier to digest.
The ability to grade in a more reflective manner is also of real importance. It will benefit families of service users to have more updated information on the standards, quality and concerns relevant to the provider. For families this is a real positive, and will likely act to support relationships with stakeholders.
Single assessment framework
One of the most important changes is the CQC’s move to a single assessment framework – a strategy that was first introduced in 2021 with the aim of putting the emphasis on care integration, people’s experiences, cultures of safety and learning.
Previously, there were different frameworks for the type of service being administered – e.g. hospital care vs adult social care – and for registration and inspection.
The main change with the single framework is to move away from the CQC’s Key Lines of Enquiry (KLOE) to quality statements which providers will now be measured against. This is intended to remove duplication and complexity by setting out one set of overall expectations that apply universally.
Building in greater clarity
The CQC has recognised the need for clarity on the changes, how they will be implemented and any variations in the requirements from providers.
To help understand the new single assessment framework, the CQC has illustrated it using a pyramid, which reduces 300 lines of enquiry down to 34 quality statements.
Moving down in chronological order, the top of the pyramid focuses on the ‘five key questions’, which ask whether a care service is safe; effective; caring; responsible; and well-led. These remain the same as before.
The next step down is quality statements, are also known as ‘we statements’. These are examples of behaviours and actions that reflect the five key questions at the top of the pyramid and are designed to keep the focus on ‘high-quality, person-centred care.’
The bottom two levels of the pyramid refer to the evidence-gathering stage, with the latter stage more bespoke and specific.
The aim of the single framework is to better streamline the process. The CQC hopes this streamlining will also improve waiting times for results – something that has caused concern in the past. Waiting times have also caused issues for providers hoping to improve their gradings – impacting their status with commissioners and stakeholders.
The importance of data
There will now be far more reliance on data. For providers that are not data ready this could be a real challenge, especially where paper based systems remain in play. This is particularly important for areas such as nursing staff, where changes in recording and systems are a key part of their daily undertaking.
The CQC aims to use data more effectively via a range of audit tools in order to simplify the process, tailoring its assessment to different services and to have one framework. The sector should welcome the use of technology and data to streamline what has always been a complex and often subjective process. The ability for changes made by the providers to address any issues identified in an inspection and have the capability for those changes to be recognised in their rating is a significant plus.
Rolling out the changes
The CQC has been open in its process for the implementation of the new framework. Since the change in approach was first announced in March, the timetable towards its wider rollout has been explicit.
From August, the CQC began rolling out various elements of the new framework to a select group of early adopters. The first group to be invited comprised home carers who had not yet engaged with the CQC’s registration process.
In September, we saw the number of early adopters expanded to include some GP practices, independent providers, and care homes.
October saw the CQC began carrying out its first assessments using its new approach, again with a small group of early adopters and new services registering.
The early adopter pilot schemes will close at the end of the year, and the CQC has stated it is aiming to report its learnings early in the New Year. The commission is aiming for a full rollout in 2023, when it plans to begin assessing all providers using the single assessment framework.
We are likely to see greater regulation of Local Authorities with the CQC likely to focus on providers in an areas where the LA is failing. Previously LA’s have not been inspected so this is something new that could have major implications. Providers are already feeling the effects of LAs preparing for this change.
The CQC is taking an iterative approach to these changes, and we don’t yet have all the details, leaving some providers unsure about how best to prepare. Markel is already supporting clients with preparation, and we’ll be providing guidance on the new process every step of the way.
While the process of CQC inspections will be streamlined the devil is all too often in the detail and the results of the pilot schemes and any changes to the approach from the CQC which arise will need to be carefully considered in the months to come.
Charlotte Rowe is Care Practice Manager at Markel Care Practitioners – https://uk.markel.com/services/markel-care-practitioners
