CQC Single Assessment Framework Implementation – an Update

It is well known that there has been widespread dissatisfaction amongst providers regarding CQC’s initial implementation of the new Single Assessment Framework (“SAF”).  We have recently supported a provider client in bringing a challenge to CQC’s processes and there have also been significant concerns raised by trade association representatives.

In the light of this, it is pleasing to see that CQC has engaged and is making some changes to the implementation of the SAF which appear to address some of the concerns.

Numbers of Quality Statements Assessed and Awarding New Scores on the basis of Previous Key Question Ratings

We have previously[1] highlighted concerns that SAF assessment reports would not properly reflect the current standard of services, where those standards had changed since the last inspection, due to:

• the small number of Quality Statements assessed being insufficient to ‘tip the balance’ in the scoring; and
• the practice of applying scores to the other Quality Statements on the basis of the rating awarded to the relevant Key Question at the time of the last inspection.

Against these concerns, we understand that more recent assessments conducted by CQC under the SAF appear to be reviewing an increased number of Quality Statements (an average of 11-12).  Most importantly, we note that CQC’s Chief Executive, Ian Trenholm, gave a commitment in a blog last week that:

“when carrying out an assessment of a service that is either Inadequate or Requires improvement all Quality Statements under the Key Question(s) that are rated Inadequate or Requires improvement will be reviewed.”

This is a particularly welcome development and should address long-standing concerns about services being stuck with ‘Requires improvement’ ratings for a number of years, even though any shortfalls in standards have long since been addressed.  It should also mitigate against difficulties seen in some early assessments under the SAF; such as the translation of old Key Question ratings into new scores for Quality Statements which are not assessed afresh misrepresenting the actual findings which CQC made at the time of its last inspection - see for example the scores of ‘2’ awarded for Quality Statements under Effective in the assessment of C&S Makenston Special Care Service[2], even though the findings for the majority of the equivalent KLOEs at the time of the previous inspection were positive.

CQC’s willingness to engage and amend its processes in this way is welcome. However, there are still a number of concerns regarding the way the SAF is being implemented which we are discussing with clients.  These include:

• Lack of Detailed Quality Indicators – without further detailed guidance for inspectors and assessors, there are risks of inconsistency regarding:

·    what factual matters inspectors/ assessors should take into account when assessing whether a Quality Statement is met; and

·    how inspectors/ assessors decide whether any particular piece of evidence should be scored (as a ‘1’, ‘2’, ‘3’, or’4’).

• Lack of Triangulation of Evidence – CQC’s guidance states that, after it has assessed a Quality Statement for the first time, it does not need to review evidence in all the key Evidence Categories for that Quality Statement subsequently.  This presents a risk that if, after it has assessed a Quality Statement for the first time, CQC receives new evidence from a particular source regarding that Quality Statement, it can then form a new judgement and re-score that Quality Statement solely on the basis of that single piece of information without having to corroborate it.  In view of this, it would be helpful for CQC to clarify how it will ensure that there is proper triangulation of evidence before judgements are made.
  
  
• Recognition of Outstanding Services – although CQC has now committed to assessing all Quality Statements in Key Questions rated Inadequate or Requires improvement to ensure SAF assessments properly reflect changes in standards in those services, there is no equivalent commitment for services seeking to improve ratings from ‘Good’ to ‘Outstanding’.  We understand that it should be possible for a provider to request a widening of the scope of an assessment (to cover additional Quality Statements) where this is supporting evidence of improvement. However, there is no clarity as to the mechanism for making and responding to such requests. Previously,  some of our clients have reported that they attempted to ask for more Quality Statements to be reviewed during an inspection but that the inspectors were not receptive to that.
  
  
• Factual Accuracy Challenges – CQC’s guidance on Factual Accuracy challenges does not permit providers to raise challenges, prior to publication of the report, that the Evidence Category scores awarded to particular factual findings are inappropriate.
  
  
•  Transparency of Public Reports – it would be helpful for CQC to change the way information is  displayed on its website to make it clear as to the dates of all the factual findings on which its SAF assessment scores are based.  At present, for Quality Statements scored on the basis of the rating awarded to the relevant Key Question at a previous inspection, the SAF assessment report gives no indication of the date of that previous inspection (which may have been a number of years previously).

As the implementation of the SAF beds down over time, it will be crucial for providers to continue to engage with CQC to ensure it makes further changes to its practices and guidance to address these additional concerns.  We continue to support providers in engaging with CQC around the SAF and if you wish to discuss any of the issues discussed in this alert, please contact:

Carlton Sadler

Siwan Griffiths