CQC has issued a further Consultation only a couple of weeks after launching its Consultation on its 5 year strategy. This new Consultation, titled “Consultation on changes for more flexible and responsive regulation”, focuses on CQC’s planned future approach to its quality assessments and awarding ratings.
Whilst this more recent Consultation is relevant to all CQC registered health and social care providers in terms of the approach, there are some significant changes planned for rating NHS Trusts and GP Providers.
In brief, the Consultation notes the following:
Assessment of Quality
As CQC indicated in its draft strategy, there will be a marked move away from reliance on comprehensive onsite inspections as the trigger for assessing quality and issuing ratings. Rather, CQC will place more reliance on good quality data from a variety of sources, including service users’ feedback, combined with focused onsite inspections where necessary, to assess quality and change a rating. CQC is confident that there is now better data available because of the wider use of digital technology in health and social care, and it has also improved IT capability (including Artificial Intelligence) to analyse information and provide a more up to date assessment of quality within an organisation.
CQC has already stated in its draft strategy that it wants a less rigid approach to enable ratings to be changed for fluidly and gone are the days of a change of rating being determined by the frequency of the inspection. CQC confirms that it will not be necessary for it to undertake an on-site visit for ratings to change. Rather, in its ongoing assessment of a service, ratings will be changed accordingly.
There is no further detail at this stage on how the frequent change of ratings will work in practice. We will have to await further information, but, whilst more dynamic changes in ratings to more accurately reflect the true quality of services on the ground is to be welcomed in principle, it will be important to see how this works in practice. It appears that the move might result in CQC having greater discretion not only as to the judgements to apply to ‘factual findings’, but also as to what data is taken into account and what may be the tipping point at which information ceases being merely background information relating to a service and becomes the basis for a new rating. It will be important to ensure that there is consistency in CQC’s practice around this and this will be an interesting space to watch.
Ratings NHS Trusts and GP Practices
CQC’s ambition is to evolve the ratings given to providers to make them easier to understand, more relevant and accessible for health and care providers and people who use services. No changes are currently intended to the aggregation of the 5 key question ratings for social care providers, but key changes are intended for GP practices and NHS trusts during 2021.
A simplified ratings system will be introduced. This will mean that CQC will no longer rate individual population groups as it does currently for the effective and responsive domains. Rather, GP practices will have two levels of ratings:
Level 1: A rating for each of the 5 key questions for a location.
Level 2: An overall rating for the location. This will be aggregated from the 5 key question ratings above.
CQC are removing the population groups ratings because it says there is little variation in ratings for different population groups and providing care to specific population groups is often influenced by wider local health systems. However, CQC will continue to monitor how practices provide personalised and proactive care to the local populations, and consider people’s different needs when receiving primary care, in its ongoing assessment of a service.
NHS trusts will also be subject to a fairly significant change to move away from the current system where a trust can be subject to a complex calculation to determine its overall Trust rating. In the future, a NHS trust will get a single overall rating at Trust level, rather than the current approach of also having trust level ratings for each of the five key questions. This single overall rating will be based on CQC’s overall assessment of the organisation’s performance against the key question of Well-Led, including findings from service level assessments. However, CQC will still continue to publish ratings against the five key questions at core service and location levels.
CQC states that the above changes are needed for NHS trusts because the current system to determine the overall aggregated Trust rating is too complex and can conceal variation in the quality of services. Further, aggregated ratings relying on inspection at service level can become out of date quickly and such ratings do not always reflect the way people experience services and care.
In simplifying ratings in this way, CQC states it can focus more on the culture and leadership within an organisation, as well as the services where people receive care. It appears that this move will result in an even greater focus on ‘Well led’ in determining a Trust’s overall rating; however, the detail as to how this will work is still awaited.
The current flurry of CQC Consultations may be among the last of this type we will see for a while. In line with its overall strategy of wanting to be a more agile and flexible regulator, CQC believes its current approach to Consultation takes too long and does not enable it to respond quickly to the changes needed. As such, moving forward there will be less formal Consultations undertaken by CQC; rather the idea is that CQC will be listening and engaging with people on a more ongoing basis, enabling solutions to be designed together.
Should you wish to respond to the Consultation, all responses must be sent to CQC by 23 March 2021. The Consultation document can be found here Consultation on changes for flexible regulation | Care Quality Commission (cqc.org.uk)
Join us at our seminar to discuss the future changes
We will be holding a seminar, in conjunction with Laing Buisson on 10 February 2021 to discuss the new draft Strategy and CQC’s new approach. Joining us at the event will be members of CQC’s policy team. Should you wish to join the seminar, please sign up here.
The Consultation promises wide ranging changes in the way CQC will regulate the health and social care sector including:
- even greater emphasis on the experiences of people using services;
- more dynamic and improved reporting on the quality of services;
- stronger focus on safety cultures;
- raising the bar for ‘Good’;
- doing more to support providers to improve services;
- championing innovation and technology-enabled services; and
- potentially requiring the additional registration of parent companies in corporate groups.
It will be important for the sector to engage with the Consultation and this webinar will give providers and investors an opportunity to hear more from CQC on the draft strategy and raise issues to inform the response.