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Smarter Regulation – what it means for providers? (Part II – Understanding CQC’s new vision)
In a bold new vision, the Care Quality Commission (CQC) has set out a strategy, which it says combines “learning and experience” with “valuable contributions from the public, service providers” and its partners.
As a result, the CQC says its strategy, which covers four key themes (‘People and communities’, ‘Smarter regulation’, ‘Safety through learning’ and ‘Accelerating improvement’), will be more “relevant”, more “flexible” and more “responsive” to cope with the ever-increasing challenges that the social care sector faces.
The CQC also says that the new directive will ensure that it achieves its core aims - to not only ensure that social care providers deliver “safe, effective, compassionate high-quality care” but that the CQC gives them the tools to change.
Ed Watkinson, a Regulatory Specialist explores, examines and demystifies the four key themes that make up the new strategy in 4 parts. This time, he discusses what smarter regulation means for providers.
Smarter Regulation – what it means for providers
The CQC has promised that it “will be smarter” and regulate “in a more dynamic and flexible way”. But what does this really mean?
Firstly, one major tangible change, is that there are likely to be fewer site inspections in the future, and when they occur, the CQC inspections teams will be much less scheduled in their approach. The CQC may turn up with little warning, but it will come prepared with lots of data and intelligence that it has gathered from a range of different sources including agencies, local authorities, commissioners and the National Health Service. If inspection teams do deem it necessary to inspect, it will be because they want to see practice in action, or because the only way that they feel that they can properly assess the service, is by talking to front line staff, managers, service users and their relatives.
This marks a departure from the CQC’s previous commitment, which was much more linear and binary. The CQC said simply if services were rated as inadequate, they would be re-inspected three months later and if services were outstanding, inspectors would return three years later. In my view, there were some flaws to this approach, which the CQC have recognised. For example, it fails to take into account the fact that services can go from ‘Outstanding’ to ‘Inadequate’ very quickly. It only takes a highly experienced front-line manager to leave, or a service to receive a number of complaints, for the quality of the outcomes received by service users to slip away.
Hopefully, this more data-driven approach to inspection will enable the CQC to be much more responsive and agile when it comes to inspections. I think that the CQC’s desire to develop much more of a relationship with providers than before will also be appreciated by providers. In understanding how providers function and the challenges they face at a local level, the CQC will be in a stronger position to work with services to suggest preventative measures before smaller issues develop into bigger problems.
As the CQC moves towards a culture of continuous monitoring, it is unclear whether the CQC will insist on providers filling out the Provider Information Return (PIR) once a year, or whether it will be slowly phased out. Until this point is clarified, however, services should continue to complete the form.
With the CQC choosing to embrace continuous monitoring, this is where content platforms like QCS, the leading provider of content, guidance and standards, come into their own. With access to a myriad of policies, procedures, auditing and risk assessment tools, front-line providers have all the tools they need – whatever setting they find themselves in – to deliver high-quality care.
In the new strategy, the CQC states that it is will “co-ordinate data collections”. The CQC is keen to use data more effectively to avoid “duplication” and “workload for services”. It plans to share the information it gathers through “data-sharing agreements”. How exactly this will work and what technology the CQC will use to manage the process is unclear. But if enhanced data sharing enables the CQC and the services that it regulates to carry out more dynamically managed inspections, then it could allow for the CQC to change the rating of a service without undertaking a site visit. Or, if an inspection is required, the inspection and rating process is likely to be a lot more fluid. The written reports will change too, in so much that they won't be long and convoluted texts. Instead, they will be much more accessible and targeted for a particular audience. They will also be more widely promoted and service users, those regarded as important to them, and a range of different services will be more clearly informed about the work of CQC and the services of interest to them.
Real improvement or a raft of unanswered questions?
Will smarter regulations work? Perhaps it is cliché, but they say ‘the proof of the pudding is always in the eating.’ Therefore, I think it very much depends on the quality of information and sources that the CQC receives when considering whether or not to change a rating. Two key questions which the CQC is yet to answer are ‘how much evidence will inspectors need to consider a rating change’, and ‘will the CQC change rating for each of the five key questions, but not actually change the overall ratings?’ We simply don't know, but I believe that there is no substitute for face-to-face inspections.
In the third article, Ed Watkinson will be focusing on ‘Safety through learning’.
You can read part I of 'understanding the CQC new strategy' here
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