CQC specialist adviser Tracy Green explains the new approach to CQC inspections and how practices can prepare
You will have heard by now that the Care Quality Commission (CQC) has changed the way it inspects providers. This may feel daunting so I will explain what the key changes are and what they mean for your practices.
The CQC regulates health and social care in England and works in hospitals, hospices, dentists, care homes and, of course, in general practice as well as other providers.
Its new inspection regime is a move to a single assessment framework, which will be used for all providers albeit with variations in the quality statements and evidence gathered.
The CQC has said it needed to make these changes to:
- make things simpler so they can focus on what really matters to people
- better reflect how services are delivered by different types of service as well as across a local area
- have one framework that connects the registration activity to their assessments of quality.
What are the main changes?
The main changes to be aware of are:
- A move to an ongoing assessment and risk based approach
- Use of key quality statements
- Making comparisons
- A new portal to upload documents
- How ratings are calculated
- How ratings can be changed without a full on-site inspection.
An ongoing assessment and risk-based approach
How does this change affect practices?
The easiest way to explain is to liken it to how students are assessed at college or university.
Some will have traditional exams on a set date for which they revise, prepare and cram for. Others may be on a BTEC course, with assignments and projects on which they are assessed and continually evaluated as they progress through their studies.
The exam scenario is akin to the former inspection regime which is more of a snapshot judgement. The second scenario is more similar to the approach the CQC will be taking now.
So, what does this mean in practice?
Similar to the monthly remote monitoring that has been in place since 2021, CQC teams will continually be looking for and reviewing evidence and data. They will be interested in a variety of information including, and not limited to, notifications submitted through the portal, feedback given directly to them and any discussions with stakeholders such as commissioners or nursing homes the practice looks after.
CQC teams will also look at publicly available data of which there is plenty, and they will expect key people such as the registered manager or practice manager to have knowledge of this data.
It’s worth taking the time to get to be familiar with data in the following information sources, so you can be as up to date as the CQC:
- Public health data at Fingertips
- QOF
- General practice workforce data at NHS Digital
- GP Patient Survey
- General practice data dashboards
- Practice list size and GP count for each practice.
Do be aware that publicly available data will not be as up to date as data you hold within your clinical system for things such as QOF.
Key questions and quality statements
Some good news is that the five key questions remain to assess each service. An easy to remember acronym for these is SCREW.
These are:
- Is it safe?
- Is it effective?
- Is it caring?
- Is it responsive to people’s needs?
- Is it well led?
Key Lines of Enquiries (KLOEs) no longer have a place within the single assessment framework. There are 34 quality statements underneath these key questions that I will cover off in more detail in a separate article.
Making comparisons
As part of the ongoing risk-based approach, the CQC will make local and regional comparisons to inform its decision making.
It will do that to gain assurance of patient safety and decide who, if anyone, the CQC feels it needs to make further contact with and/or arrange an on-site inspection with. It will do this by gathering evidence remotely, including through any discussions with the provider or stakeholders.
A new provider portal
Practices will receive an email inviting them to register for the new provider portal. No action needs to be taken until the email is received. The plan is to use the new portal for providers to upload evidence from the end of March.
Ratings calculation
To support the transparency and consistency of its judgements, the CQC will introduce a scoring framework into its assessments. Where appropriate, it will continue to describe the quality of care using the four ratings: outstanding, good, requires improvement, or inadequate.
When the CQC assesses evidence, it will assign scores to the key evidence categories for each quality statement that they are assessing. Ratings will be based on building up scores from quality statements to give an overall rating.
Rating changes without an on-site inspection
In my opinion, one of the biggest changes within the new framework is the ability for the CQC to change a provider’s overall and/or key question rating without carrying out an on-site inspection.
For example, a practice or provider rated as ‘requires improvement’ for the ‘caring’ key question category may subsequently provide evidence that was not previously available, which the CQC can then review and, if appropriate, increase the rating to ‘good’. This may or may not lead to a change to the overall rating, of course.
Still, we know that focussed and follow up inspections have taken some time in the past which can be frustrating when you have made practice improvements and want your rating to reflect that. I feel this is a positive move and it will be interesting to see how this works on the ground.
When do these changes take place?
These changes were piloted at the end of last year. They are currently being rolled out region by region and the new inspection regime is due to be in place nationally by April 2024.
The CQC plans to use the information and findings from the pilot groups to inform future decision-making including on regularity of on-site inspections.
What do I need to do now?
All practices and providers must understand the new framework and how they can be compliant but also how to provide evidence of their compliance.
My advice is to carry out an honest self-assessment against all the key questions then draw up action plans with assigned ‘owners’ as well as set completion dates. This will mean you are working as a team to ensure you are CQC compliant at all times.
If you need support, get in touch with a consultant or a colleague who can provide guidance and direction on creating that baseline assessment and developing an easy-to-follow action plan.
Tracy Green is a primary care business consultant and CQC specialist adviser. She has worked in primary care for 16 years
