Last reviewed 7 September 2020
In this feature, Deborah Bellamy discusses the proposed new changes to CQC regulation and other developments.
The CQC acknowledges that coronavirus presented an unparalleled challenge for providers across health and social care. It witnessed the fortitude and willingness of providers to think differently to meet the needs of people who use its services and maintain their safety in a time of crisis.
As we move towards winter and potential further coronavirus (Covid-19) spikes, the CQC is keen to capitalise on collaborative approaches and harness this momentum, continuing to provide optimum experience and outcomes for those accessing care.
Moving forward, the CQC’s plans are to continue to focus on higher risk services, launch a Transitional Regulatory Approach, and to consult on its next strategy.
CQC during the pandemic
During the Covid-19 pandemic the CQC’s regulatory role remained stable. It adapted its standard regulatory approach by pausing routine inspections and only inspecting based on risk or where there were concerns around people’s safety and human rights. This enabled providers to focus on responding to the pandemic situation, avoided CQC inspectors unintentionally spreading the virus and reduced demand for scarce personal protective equipment supplies.
To make optimum use of new technology platforms developed and innovative ways of working, CQC regulation looks set to significantly change over the forthcoming year. The impact of the pandemic means that changes that would usually have been rolled out over a number of years are being implemented in a matter of months.
A short survey is available for completion at: cqc.citizenlab.co. This looks at the CQCs “monitoring” aspect focusing on safety, including aspects of leadership in a service and access to a service.
Primary care pilot
One approach to regulation change, will be via a pilot looking at the assessment and monitoring approach with a small number of general practices. This will provide the CQC with the opportunity to gather evidence from providers without crossing the threshold.
Inspection teams plan to work remotely as far as is possible and will digitally access clinical records for assessment where required.
Work will be focused on areas of risk and at this stage, used where CQC have assessed potential risks to patients or existing breaches of regulation and for practices currently in special measures.
This is not an inspection and therefore will not result in a rating with participation being voluntary. Any participating practices will be informed of the implications and this approach should enable information gathering from a provider in a more flexible and responsive way which is less disruptive and necessitates reduced input.
Practices will be contacted by the CQC with further detail, including proposed safeguards ensuring information security.
Emergency Support Framework, home care tracker and Covid-19 testing
Back in May 2020, a new monitoring tool, Emergency Support Framework (ESF), was released at short notice by the CQC. This represented adaptation of customary regulatory approaches, using data and feedback to identify problems in real time, offering advice and support.
It was developed to enable inspectors to understand where people could be at the greatest risk of unsafe care and initially used with:
health and care providers in the criminal justice system
independent doctor and clinic services.
It was intended to be rolled out further, but this will now be superseded.
A new home care tracker was also introduced, designed to work alongside the NHS Tracker for adult social care to help monitor risks to the quality of care.
At the request of the Government the CQC also supported testing of staff and residents in adult social care services, a real deviation from usual activity.
New Transitional Regulatory Approach
From September 2020, CQC will introduce a Transitional Regulatory Approach, which will combine existing methodologies with learning from Covid-19 response and include visiting providers, as it is aware this needs to change.
The CQC monitoring approach will encapsulate a broader range of topics as part of the monitoring process and use information available to present a clearer view of risk and quality. This will be done by means of developing the approach fostered by ESF to explore more issues that matter to people.
They will develop clear areas of focus for monitoring, based on existing Key Lines of Enquiry (KLOE) specifically targeting safety, access and leadership with a view to continue to iterate areas of focus throughout the autumn with increased emphasis on other areas, such as improvement cultures.
As the risk of coronavirus recedes and on-site activity re-established, scope will be increased to include services where they have evidence care needs to be improved as well as services where they have evidence service users may be at risk.
The CQC plan is to balance its approach, ensuring they listen to people’s experiences of care and create an accurate assessment of quality whilst minimising infection control risks. The revised format is likely to move away from the CQC’s traditional methodology with exploration into ways of publishing material online. Significant work has been carried out on CQCs digital capabilities to enable this.
Provider collaboration reviews
The speed and scale of the response required by the pandemic has highlighted the importance of collaboration across the health and care system. Responses to the pandemic have led to more partnership working, ensuring shared efforts to avoid fragmentation and to drive forward best experiences and outcomes for those accessing care.
Building on this work, the CQC has commenced a series of rapid reviews focusing on 11 Integrated Care System and Sustainability and Transformation Partnership areas. These Provider Collaboration Reviews will share examples of where collaboration has worked well across the system, helping to drive improvements and prepare for future pressures on local care systems.
Findings will be published in September Covid-19 insight report, and this year’s State of Care report.
Before the coronavirus pandemic, the CQC carried out inspections and subsequently published a report of the findings, with each service given ratings of: “Inadequate”, “Requires Improvement”, “Good”, or “Outstanding”.
During the coronavirus pandemic, as an alternative to inspections, structured conversations with providers were carried out to ensure they were keeping people safe and enabled them to seek guidance and support. The CQC is currently reviewing how services should be inspected between September 2020 and April 2021, before the next strategy is published.
The CQC is considering a shift from comprehensive inspections, making best use of the data and information received to provide assessments of quality which are meaningful to those who use services.
As yet, there is not any clarity on what will happen specifically in relation to ratings and the frequency of inspections. Details are expected in the CQCs autumn consultation.
Potential CQC improvement arm to be established in the future
In recent provider engagement, the CQC broached the possibility of establishing an improvement arm, an innovative change from its traditional role and current position.
Prior to the pandemic, the CQC was not an advisory agency and developed this facility in response to need.
New strategy to be launched May 2021
The coronavirus pandemic has underlined health inequalities in society and amplified the collective challenge faced to keep people safe and the most vulnerable protected.
The CQC recognises health and social care has changed over the last few years and continues to evolve rapidly. For it to stay relevant, assessments of quality need to better reflect how people experience health and social care, currently and in the future. As part of its future strategy the CQC wants to explore how to take a more system-led approach to how it regulates.
A new strategy will be launch in May 2021 and there are four main themes emerging:
meeting people’s needs
promoting safe care for people
driving and supporting improvement.
There will be a full public consultation in January 2021, and the CQC is seeking feedback. A series of recent webinars or podcast episodes on the CQC’s future strategy are available and can be accessed at https://soundcloud.com/carequalitycommission.