CQC – New Fundamental Standards – Part 6, Judgement
This article will expand on the approaches to inspections which the CQC will use.
In their draft Provider Handbook published in April 2014 for consultation, the CQC sets out how it will handle Inspection Judgements from 1st October 2014.
The method of reaching a judgement does not appear to have changed. That is hardly surprising as there are not many variations possible on “using professional judgement”.
As we have seen in previous articles, the criteria on which the judgements will be reached have not changed dramatically. Much has been moved around, and expressed in different words, but in the end the major change is not in the fundamentals, but in the emphasis. This statement is, of course, true only of the upper reaches of quality care services. While poor services have always been characterised by formulaic approaches to care, with little or no understanding of personalisation, the best services have long understood the importance of individually tailored care. Similarly, safety has long been a priority for good services, hopefully leaving the scandals over abuse and premises risk to those at the bottom of the quality stack. How do the good services differentiate themselves in these two critical areas, amongst others? By attending the third change of emphasis, which is the discovery by the CQC standard writers that not much good happens in any service unless there is vision, leadership, good values and the management skills to bring these consistently to bear on the whole service.
Therefore, following the long period which it will take many providers and managers to gain an operational understanding of the Fundamental Standards, the best services will come to understand that they do not have to revolutionise their service, but think about it differently. The publication, in the Provider Handbook, of quite detailed information about the evidence which the CQC will look for has given an insight into this previously opaque area, allowing the interested service to create measurement tools to find out before inspection how they think they may be performing. It is a characteristic of a good and well-managed service that it normally has a fairly accurate idea of its own performance levels, and does not receive too many surprises - everyone is proud of that they do and want to do it well.
Below par services will, however, have a hard time. It is possible that poor services work in relative ignorance of their legislative responsibilities anyway, and the shuffling around of the requirements can only exacerbate that problem.
Ratings are back
One major change will, however, focus minds on improving performance, and that is the return of Ratings. No longer is it sufficient for a service to simply claw its way over the legislative threshold by a tiny margin – in the old inspection regime, no differentiation was made between “only just made it” and “exemplary”, so for some the attitude was, “why bother?”.
Ratings change all that. When all CQC registered services will, between October 2014 and April 2016, be awarded a rating ranging from ‘Outstanding’, to ‘Good’, down to ‘Requires improvement’, and finally ‘Inadequate’. With the possibility of poor services being publicly labelled ‘Requires Improvement’ or even ‘Inadequate’, there will be plenty of incentive to improve. Even the top range of services will be striving to reach or retain ‘Outstanding’ – it is in their nature to want to be the best.
What does this mean on a day-to-day basis? As outlined in the previous article on Evidence, the gathering of evidence of how well you are working is no longer an option. It is an essential part of daily management, in order to clearly demonstrate how your service is performing, and how you are managing it towards improvement, wherever it is now.
How can QCS help?
For those using the QCS Compliance System, the process will be a little easier. QCS has published within their management system – soon available to all existing and new clients - a set of tools intended to help services cope with the new inspection regime with relative ease. The tools are:
- A complete suite of Surveys, focused on the Key Questions - for Service Users and their advocates; their families; professional advisors, and staff. Many of the KLOE prompts cannot realistically be supported by direct documentary evidence; the criteria are based on the Service User’s feelings and understandings, which can only be evidenced by formal surveys.
- A Mock Inspection Toolkit, with checklists of evidence required for each KLOE.
- A new Policy for each KLOE, listing those QCS Policies and Procedures which contribute to the achievement of that KLOE. Also included in each Policy is a narrative explaining the processes, based mainly but not exclusively on the QCS Policy pack, that are required to be in place and successfully running in order to generate the evidence to be found when carrying out the Mock Inspection.
- A renewed emphasis on the management and quality assurance processes which have always been a key element of the QCS system, but which in the past were advisable but not so critical for simply reaching the regulatory threshold. In the new regime they are critical, and we point this out at numerous points in the new tools.
In addition to these innovations, QCS has developed a new approach to Mock Inspections, Surveys, Supervision and Training which will, in our opinion, significantly enhance performance and therefore legislative compliance.
Next week, the final article in our series of New Care Standards guides will outline how the new Ratings system works from the CQC point of view, and try to tease out what the strategies of providers and managers should be in order to achieve their best outcome from the rating process.
In Part 1 of the series we have seen how the Care Quality Commission has proposed to implement from October 2014 a new regime of registration and inspection in response to failures of the current regime to spot and deal with poor quality care before too many people were harmed.
We saw that the CQC proposes a new, clarified and re-focussed registration and inspection regime, demonstrated by the following schematic.
The schematic demonstrates that the CQC regard their overall registration process as having five steps, these being:
- Intelligent Monitoring
- Expert inspections
- Judgement and publication
- Action, if indicated by the inspection outcome
(Provider Handbook (Adult Social Care) Consultation, Page 2)
The scope of each of these processes is based on the new definitions of quality, these being:
(Provider Handbook (Adult Social Care) Consultation, Page 2)
Michael Dempsey - QCS Compliance Director