For the last two years, the Adult Social Care (ASC) sector has been struggling with the complexities and clunkiness of the Single Assessment Framework (SAF). As we all know, there have been escalating problems with the SAF – from ineffective IT systems, complex scoring, poor organisational management and ultimately a blinkered approach that made it very difficult for issues to be heard.
However, things now appear to be changing with the CQC sorting out its leadership, listening to the views of people, learning from past mistakes and voicing a determination to get it right this time, but it is ironic that to get it right we have to almost go back to what it was like before the SAF.
The CQC’s latest consultation, ‘Better Regulation, Better Care,’ details this change and is suggesting a pivot from 34 Quality Statements to 24 KLOES. But it is more than just a reduction in number; the whole focus has changed from statements about what is expected, to questions about what providers are doing to meet the area concerned.
This approach seems to sit more favourably with providers, providing an opportunity to show evidence and explain what they are doing, and allowing flexibility in the range of evidence.
In addition, CQC is returning to sector-specific directorates and ways of working and it is felt that this will make regulation more ‘person-centred’ and focused on assessing the quality of the actual service provided, rather than a SAF ‘one size fits all’ approach that landed very badly with services, and was not nuanced enough to be effective.
All this is going to be supported by another tool that was in place before the SAF, ‘characteristics of ratings’, which detail what a service looks like for each of the 4 ratings under each KLOE. This means providers will have a ‘benchmark’ that they can compare themselves to, and what they should focus on to improve.
Another area that is being rolled out with Primary Care services and may well be used with adult social care is a focused inspection methodology called ‘Return to Good’. On the face of it you might think that this is about promoting a drive for all services to be rated good, but it appears to be focused on services that have historically been rated good and returning to them to ensure that they are still good. I’m sure CQC has given this thought, but it does seem to be an odd approach with limited resources and to be ignoring services that are identified as in need of regulatory intervention.
If it is used in social care, it will be an indicator that if you have a good rating and haven’t been inspected in over two years you need to get your evidence in order and prepare for a visit from CQC.
CQC is also looking at its report format, and shortening reports to improve quality and accessibility, and to try to spend less inspector time writing reports. These are being trialled during April and May. We will need to see the revised format but hopefully the content will meet the needs of the provider and the public.
On the back of CQC returning to individual directorates, it is developing a more personal approach to relationships with providers, with the hope that services will have a named person as a ‘provider oversight lead’.
As we can see there is still a lot going on with CQC, but most of it is below the surface. Thinking is being refined rather than a roll out of new ways of working for all providers.
CQC is still holding events and listening to feedback to further refine thinking and approach, and this is on top of the current consultation.
However, while all this is going on, CQC cannot stop activity and is still using the SAF to inspect, write reports, rate and enforce services. This must be a challenge for them as they are balancing the need to be an effective regulator, with recognising that the systems are in dire need of improvement.
CQC is still enforcing against the regulations, and it is interesting to note that Regulation 17, Good Governance is by some margin the fundamental standard that providers fail to meet most often. Breaches should be easy to avoid if you have good audit systems in place, action plans are completed, evidence of the work you are doing is able to be shared and the management of the service work well together. QCS Compliance Centre can guide you through everything you need to do, and how to do it. There’s also QCS Audit Centre which can specifically help you with your auditing needs.
Finally, it really looks like the KLOES included in the consultation will be what is used going forward, so it would be worth changing your mindset now and looking at the evidence that you have available, ensuring all staff are aware of the KLOES and what this means in practical terms for the service.
We will be writing further updates when we know more, but for now, get involved with the CQC consultation, attend events, sign up for newsletters and be as ‘tuned in’ as possible to CQC thinking and ideas so you can be as ready as possible when things do change later in the year.