- Posted Wednesday July 21, 2021
In May 2021 the CQC launched their new strategy plan to be rolled out in the coming months, following public consultation earlier in the year. Characterised by themes of increased collaboration and smarter working practices, the strategy has nevertheless been criticised for perceived failings in some areas. Here we look at the main elements of the new strategy, and explore some of the challenges and concerns that have arisen.
The CQC’s four main pillars and their aims are:
- People and communities – regulation focussed on what really matters to individuals and their communities when they interact with health and care services.
This encompasses three strands: (1) Listening and acting differently, i.e. making it easier to give feedback, and being clearer about what tangible actions have been taken as a result of it. (2) Empowering people, which means people have to know who the CQC is and what it does; they have to be engaged with the CQC to drive change, and people must know what good care looks like, so they have examples of best practice and can make informed decisions about their care. (3) Prioritising people and their communities, involving people in designing new care services and improving existing ones, better assessment of whether local services are meeting local needs, and understanding all factors which create health inequalities and affect patient outcomes.
- Smarter regulation – ensuring regulation is flexible and dynamic and can provide real time information; making working with the CQC easier; ensuring more proportionate responses.
(1) Taking the right action at the right time, meaning moving away from relying on scheduled visits and assessing more flexibly. It also means having better quality conversations, talking more with staff and patients, and working smarter, with AI, digital tools and big data. (2) More meaningful ratings, i.e. ensuring they reflect people’s individual experiences of care, and being clear about what assessment criteria were used. (3) Making it easier to work with the CQC – being careful not to make duplicate or onerous requests for information, making the methods of submitting info easier, and sharing data that’s currently held with organisations which can help improve care. (4) Adapting to change – being better at holding organisations to account, expanding the definition of what a ‘provider of care’ is, looking at how people move between services, and better understanding the risk of variation in experience. (5) Being relevant for all – moving away from longer written reports, having clearer definitions of ‘quality,’ and making all information more accessible and user-friendly.
- Safety through learning – advocating for safe cultures in the NHS, focussing on learning, improvement and collaboration.
The basic elements of this goal are: (1) Culture is important - a culture of safety and learning should be embedded in everything the CQC does, where people feel safe when they report things and lessons are learned. (2) Building expertise – asking how we judge whether services and systems are working, and adding expertise where needed. (3) Involving everyone – making sure they are partners in their own care, and have their rights taken into account, however they live their life. (4) Regulating safety – recognising that the biggest risks are when people can’t access the right care, or move between services – so the focus will be on riskier services to prevent this, and where change doesn’t happen the CQC acts quickly and shares their learning. (5) Consistent oversight – currently, oversight and support across all services is patchy and inconsistent, so focus will be on making it consistent and using insight to start the conversation about how to get there.
- Accelerating improvement – making it easier to access support, so improvements can happen where they are most needed.
(1) Collaborating to improve, i.e. working with a broader range of partners in both health and social care to improve the national picture, and at a local level working to do the same and bring in national learnings. (2) Making improvement happen – by being clearer on the standards required, and rather than telling partners what to do, they will discuss what resources they need to improve, including data, for example. (3) Encouraging innovation and research – championing technology and research that drives efficiencies. (4) An evidence-based approach – using data to properly investigate what’s needed for better quality care; using external evidence to understand this, and instilling a culture of learning and evaluation in the CQC.
Two core ambitions underscore these four areas:
- Local assessment and reassurance - providing independent assurance to the public of the quality of care in their area.
- Tackling inequalities - pushing for equality of access, experiences and outcomes from health and social care services.
However, although the broad aims have been welcomed, concerns have been raised from GPs and other healthcare professionals over the new strategy and its perceived shortcomings, in the following areas:
- Favouring smart, flexible regulation could be another way of saying there will be fewer scheduled inspections, or just less inspection overall.
- Focussing on data is a noble aim, but the data that the CQC gathers must be fully verified and put in context before the CQC start to use it to enforce action.
- The move away from long post-inspection reports has led to worries that less detail could mean vital context is missed.
- A risk-based model of inspection might create too much of a focus on GP practices perceived as ‘risky,’ meaning increasing enforcement action.
- The BMA and others still believe that the CQC needs to reform its ‘crude’ rating system so it is more representative of the truth and less time consuming – and this latest strategy announcement seems unlikely to achieve that.
- Widening patient involvement is a good aim but it’s often those who ‘shout the loudest’ or who are well-placed to be heard that get the limelight – how can we ensure that the poorest, most disadvantaged and least cared for patients are heard?
- Assessing care quality is one thing, but to make real change the CQC will have to acknowledge (and work with) a much broader section of society for the full picture. What it can do is assess how care is working to actually narrow the gaps in care provision and outcomes.
- Artificial Intelligence is an undoubted asset, but there must be full transparency about who decides on the algorithms used, what they are, and how effective they actually are in practice.
- Relying on feedback and opinion from staff and patients is only good if that feedback is given by people who understand ‘what good looks like’ and what is reasonably practicable, relevant and desirable.
- There is a worrying absence of any mention of whistle-blowing provisions and how the CQC would encourage and deal with feedback provided by a whistle blower. Many recent cases have demonstrated the importance of evidence from whistle-blowers, and such situations are bound to arise again in the future.
- It looks to some like the CQC want to direct how professionals work and what they do within the system it regulates. Some groups like the PDA think this is a fundamental mistake. They believe the role of a regulator is to create an environment where innovation and improvement can happen, without directing it themselves.
The health service in the England is at a crucial juncture; coming out of the recent pandemic, huge inequalities in care and health outcomes persist, and there is much anticipation over how (and indeed if) the country can ‘build back better.’ Given the timing of this strategy publication, it has already attracted huge scrutiny. If it is to meet its commendably ambitious targets, it must respond and adapt to the concerns raised, and ultimately deliver on its promises to improve care for all.
Head to our YouTube channel to view a brand new video from Thornfields trainer Gerry Devine on 3 Things You Need To Know About CQC Inspections in 2021.
Thornfields trainers also run courses on how to meet CQC standards, and First Practice Management members can download CQC Guidance documents now by heading to our Policies and Procedures Library.