01st November 2016

New (Interim) Inspection Methodology: Distinctively Welsh

New (Interim) Inspection Regulations: Distinctively Welsh.

Wales is currently going through a period of upheaval regarding service regulation, and a fundamental shift in the underlying philosophy of care and support delivery.  In this article we will look at the major regulatory developments. Future articles will develop significant themes. A link to the new interim regulations is provided at the end of the article.

Reasons for Change

CSSIW has recognised that an inspection framework which focuses on producing statistics and paperwork to evidence their practice has usually meant that first-hand information obtained from service users has been cursory at best, with the views of individuals often being overlooked.

Under this system, there are many examples of services receiving good inspection reports because separate aspects of provision have been classified as satisfactory due to a service’s paperwork being in order, only for later failings to come to light which reveal that actual service user outcomes have been poor. On the other hand, some services have expressed frustration when they know that they achieve high levels of service user satisfaction, only for their inspection report to be marred by a fleeting paperwork failure, which may have occurred many months before the inspection date.

Timelines

In order to facilitate a move away from this “snapshot” style of inspection to a greater focus on service users lived experiences of care and support, we are currently in the midst of several changes:

  • The Social Services and Well-being Act (SSWA) was passed in 2014, and has been implemented since April of this year, albeit without associated regulations.
  • The Regulation and Inspection of Social Care (Wales) Act 2016 was passed on 18 January 2016, which will lead to new regulations being implemented under the SSWA from April 2018.
  • From 2017, the Care Council for Wales will become Social Care Wales, and will be the single body with which service managers will be registered.
  • April 2018 will see the implementation of the new inspection regulations which, according to the CSSIW website, will be fully operational by April 2019.
  • In 2020, Social Care Wales will register all domiciliary support workers, with the same measure being implemented for residential support workers in 2022. This will have implications for staff training and development during the interim period.

Interim Inspection Guidance

The first step on this road has already started with interim inspection guidance being implemented from October 1st, 2016. This will be the inspection framework until the implementation of the new regulations in 2018.

This is providing some much-needed clarity and a road-map for the next few years. In the near future, we will undoubtedly need to turn our thoughts to the regulations in 2018 and beyond but, at this present time, our focus needs to be very much on the interim inspection guidelines which have just been published.

The inspectorate handbook frames the guidance and tells us that inspections will:

  • Be people focused –This hopefully means that the actual journey of care support and provision will be the main measure of success or failure of services. It is likely that this will mean more direct contact between inspectors, service users and other stakeholders – although simple resource constraints within the inspectorate will mean that some of this will be left to self-assessment.
  • Support improvement –This is going to include a greater acknowledgement of best practice which – under a more outcome focussed system – will hopefully be based on holistic results of service provision, as opposed to a failure in one specific administration focussed area.
  • Be transparent –The inspectors promise greater clarity in their reports to indicate reasons for judgements. While the removal of a “tick box” system of inspection is to be welcomed, there is an obvious danger of inspector subjectivity in what constitutes a “good outcome,” so it is to be hoped that the final regulations will offer very clear guidelines in this area.
  • Be fair –There will be greater opportunity for services to question the findings of inspections. This will hopefully take the form of services being able to produce evidence of positive outcomes if a report seems unfairly biased in the opposite direction, this removing some subjectivity from the process.
  • Be robust –It is to be hoped that the new focus on outcomes will result in issues  becoming more clearly reported, and focussing on where improvement is needed. There will be a focus on where there is a direct impact on the quality of the care and support being received by people using services.
  • Be proportionate –This is accompanied by a pledge to focus on “what matters most” - in other words the actual experience of receiving care and support. This will hopefully focus on the actual interface between service users and the people supporting them.
  • Be efficient –The principles highlight an increased use of ICT, which will require IT literacy on the part of managers – something which is reflected in the provision of funded vocational management training within Wales.

Four Key Domains of Inspection

Following on from these principles, between now and April 2018 the four key domains of inspection are:

  • Supporting well-being – This covers the extent to which individuals’ goals are identified and met, and their own involvement in this person-centred process.
  • Care and support – Which mainly looks at the quality of day-to-day support delivery, and service users’ contribution to this.
  • Environment – As opposed to the previous system of environmental checks, such as a health and safety audit, indicators of quality in this area are based on the environment’s influence upon safety and independence of each individual who uses the service.  
  • Leadership and management – There will be less of an emphasis on systems which support staff, and a greater focus on the quality of service leadership.

We will look at the service implications for each of these domains in future articles, but it is important that we grasp some of the main inspection changes at this early stage.

Outcomes

Within each of these domains, services will be provided with a set of Outcomes. These will be used for inspectors to evaluate the service against in detail. The outcomes are all stated in the first person, such as “I am able to express my views and opinions,” whereas previous inspections would have looked at the overall mechanism through which people’s views were sought. When meeting this outcome, services will therefore need to demonstrate ways in which they meet each service user’s communication needs.

For each Outcome, inspectors are given indicators of strong performance, phrased as “Examples of what good practice may look like.” These are again stated in individual terms.

Each Outcome is then accompanied by guidance on “What inspectors should expect to find where Well-being is judged as good.” This will allow services to plan for the types of evidence that they will need to produce at inspection, with a distinct focus on each individual’s Well-being, as opposed to evidence of a care and support system. The guidance relating to the example of “expressing views and opinions” states that “People are positively encouraged to make choices, engaged in rewarding activities and make positive use of the materials and equipment.” In contrast to previous inspection methodology, a person’s daily activities which relate to their own expressed interests are likely to be judged, as opposed to a timetable which lists a finite number of generic activities.

A More Holistic Approach

Inspectors will therefore “Evaluate the extent to which people…. (are supported to achieve outcomes).” The “Views and Opinions” example states this as “People are encouraged to speak and express themselves.”  The service may therefore be judged on examples of this in observed practice, use of advocacy or daily notes, as opposed to evidence of service user meetings.

CSSIW have now committed to inspect services according to this more holistic and individualised approach. Before next inspection, services therefore need to consider areas such as:

  • Is your organisation aware of the operational implications of well-being as determined in the 2014 Act?
  • Do your assessment and support planning systems reflect the core principles of the Social Services and Well-being Act?
  • How can you demonstrate adoption of person-centred and well-being principles throughout our care and support?
  • Can you manage or modify your environment to better meet individual requirements?
  • What are you doing as an organisation to develop your staff to meet operational challenges?
  • How well do you demonstrate individual outcomes as opposed to systems?
  • Are you able to evidence ongoing service user involvement in their own support planning?
  • Can you demonstrate examples of sound leadership?

Although the Social Services and Well-being Act received royal assent in 2014, it is only at this juncture that its’ impact is beginning to be felt by services. Whilst this time delay will have allowed some to prepare, others will find themselves playing ‘catch-up’ with the shift that the Act and the new interim regulations represent. In particular, the language around the idea of ‘person centred’ support has been further strengthened by the distinctive ‘well-being’ focus that the Welsh Government has adopted within the legislation. Furthermore, the interim regulations now provide the domains against which inspection will occur. ‘Now’ really is the time to act, for organisations wishing to be compliant with the new regulatory framework.

The new CSSIW interim regulations and ways of working for adult care services in Wales can be found HERE

*All information is correct at the time of publishing

Nic Bowler

Welsh Care and Social Services Inspectorate Specialist

Dr Nicholas Bowler is a researcher and consultant to government-level [Welsh Government Review of Secure Services, 2009] – specialising in QA/compliance focused projects. He has interests in clinically relevant training, service development and research. He enjoys working with clients to support them in identifying problems and initiating projects to improve practice.

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