The CQC’s strategy for 2016 to 2021 sets out its aim to achieve a more “targeted, responsive and collaborative approach” so that more people can receive high quality care in the future. The CQC has therefore radically changed its approach to regulating health and social care services over the last few years.
In December 2016, the CQC issued its first consultation, “our next phase of regulation”, which proposed a standardised approach across the health and social care sector for the very first time. A response to this consultation was published in June 2017 and this confirmed the changes to be made to the current assessment frameworks. A second consultation was published in June 2017 and a third one is expected for later this year so there is likely to be even more changes proposed in due course.
The CQC have already confirmed that they will be moving from their current 11 separate assessment frameworks to just two – one for healthcare, and one for adult social care. It is hoped that by reducing the number of assessment frameworks, this will improve the clarity and transparency of inspections and ratings; help providers to understand how they are being assessed; allow the public to compare services; and ensure that inspectors make assessments in a consistent way. The CQC also think that this will reduce complexity and confusion for providers that deliver more than one type of service.
However, there was some concern expressed in the responses to the first consultation that having only two assessment frameworks may be too simplified and thus, they would not be suitable across the whole of the two sectors. Although, the CQC has set out its plans to continue to develop and publish additional sector and service-specific materials that link to the assessment frameworks and provide more detailed information about how they will apply in the context of a particular service.
Whilst the five key questions will remain as the basis of the assessment frameworks, the key lines of enquiry (‘KLOE’s’) will also be merged to provide one set of questions and prompts for the healthcare sector and one for adult social care. A number of changes have also been made to the KLOE’s and these are intended to simplify the process by more closely aligning the five questions and the characteristics that reflect a rating.
The wording of some KLOE’s and prompts have been revised to provide clarity; additional prompts have been added; and some have been moved between the key questions. The new KLOE’s also include six new, strengthened themes that the CQC have deemed necessary to improve on. These include:
- System leadership, integration and information-sharing;
- Information governance and data security;
- End of life care: delivering good quality care at the end of life;
- Personalisation, social action and the use of volunteers.
Whilst this has resulted in more KLOEs overall and some duplication across themes, the majority of the content remains the same or similar to the current frameworks. The CQC have also acknowledged that some KLOEs, prompts and characteristics will not necessarily need to be applied in all settings and will only be applied where they are relevant and proportionate to the type of provider being inspected. It is, however, apparent that the new KLOE’s will need to be monitored and reviewed regularly by the CQC moving forwards, in order to measure their success and if necessary, adapt them further to ensure that they continue to reflect the most current methods.
It is envisaged by the CQC that these changes to the KLOE’s will make them more relevant by bringing them in line with changes and innovations in care and national policy. It is also hoped that the changes will encourage providers to focus on the needs of people using the services as a whole and encourage greater accountability from providers overall.
The CQC have confirmed that the new assessment frameworks for community and residential adult social care services and independent doctor services (primary medical services) will be introduced in November 2017, and primary care dental services from April 2018. The CQC have also indicated that no changes will be made to the assessment frameworks for a further two years whilst they assess the success of these new frameworks.
The success and effect of such changes will not be clear until the frameworks are introduced and therefore providers need to spend this time between now and their relevant implementation date, ensuring that they are familiar with their respective new assessment framework and updating any internal policies, procedures or quality monitoring systems which are based on the current frameworks.
If you are a registered provider or manager and you need advice or representation in relation to a CQC inspection; enforcement action; or an appeal to the first-tier tribunal, we have a dedicated team of specialist lawyers who are on hand to assist you. Call us now on 01616 966 229.