Our response to the Care Provider Alliance's review of the single assessment framework

We commissioned the Care Provider Alliance (CPA) last autumn to review our single assessment framework alongside the review by Professor Sir Mike Richards. We are grateful to the members of the CPA who took part in and supported this work.

The review examined the perspectives of adult social care providers of the assessment framework and what they want from regulation by CQC. It also raised provider concerns about assessment, registration, and backlogs.

Sir Julian Hartley, Chief Executive of CQC commented “We welcome this report which has been instrumental in ensuring we hear the voices of a wide range of adult social care providers, as the findings are a robust reflection of their views and experiences.”

Feedback represents over 1,200 respondents to an online survey and the views of more than 100 providers shared through 5 workshops.

James Bullion, Chief Inspector of Adult Social Care and Integrated Care, added:

“This report gives us a practical agenda for change which we will incorporate into our urgent improvement work underway in CQC. Professor Vic Rayner, as chair of the CPA, met with me and my Executive Team colleagues and with the CQC Board to discuss the findings of this report. She articulated a powerful message on behalf of providers, including in some cases the distressing impact of approaches to regulation and assessment on their organisations and mental wellbeing. We are grateful for their feedback and acknowledge their experience.

“We acknowledge too the strength of feeling from providers about the need to improve their experience of inspection. Underlying this report (but not looked at in detail) are the changes needed to improve our computer systems, portal arrangements and communications. CQC colleagues have themselves struggled with the challenges caused by the technology issues and rollout of the assessment framework, including the clarity of how the system worked, training, complexity of the approach, and the consistency of approaches in different care sectors. CQC inspectors are skilled and dedicated to good regulation and have struggled to be effective because of these factors”.

Our response

There are 11 recommendations in the report and key messages in the survey, which we will now work on in more detail to consider their implementation. Some recommendations will be subject to further discussion, policy change or consultation. The recommendations are detailed below.

We are already taking urgent action on our priority improvement workplan to address concerns about our performance on backlogs, assessment frequency, registration delays, and publication of reports. We see good alignment between the recommendations in this report and the work that we have already started to rebuild good regulation.

As we are currently delivering organisational change and improvement, it will be important to consider the CPA report’s recommendations effectively alongside existing work. We are determined to improve providers’ experience of regulation with the development of a handbook which describes what we expect from providers, what they can expect from CQC, as well as giving our staff the tools and time to do their job. We are strengthening sector leadership in CQC and want to continue to work with the CPA to oversee progress. This report provides a good agenda for shared work over the coming months.

Recommendations

1. Create a reduced set of quality statements (the specific numbers suggested by providers were all under 20) and assess all providers on a consistent set of statements for every routine inspection. This should reflect a meaningful reduction in the burden that the assessment framework imposes on providers, rather than condensing the same workload into a smaller set of quality statements.
   • The ‘standard set’ of quality statements applied to each service type may flex to the elements of service delivery most relevant to them
   • Shared Lives providers were the only group to differ in this regard and would prefer flexible and more frequent assessment drawn from a reduced set of quality statements.
2. Create guidance for each service type at the quality statement level. Each set of guidance should include specific examples of what good and outstanding looks like and highlight where an aspect of a quality statement is not applicable to the service type.
3. Use the information in the Provider Information Return to plan a timeline, CQC staffing, and priorities for assessment.
4. Share this assessment plan, including evidence requests, with providers and give them advance notice of inspection.
   • Evidence requests, assessment timelines, and number of inspectors must be reasonable and proportional in their scale of demands on services.
5. Ensure that evidence included in decision-making has been corroborated rather than taken at face value, to produce a balanced appraisal of the service and is not wholly focused on finding issues or risk.
   • Detail efforts made to triangulate information in the report.
   • Increasing the rate of inspections does not help providers or the public if the assessment process and report are not meaningful and reflective of the findings on the day of inspection.
6. Re-write the reports of providers who have been assessed in the period of time between the implementation of the SAF and the stabilisation of the regulatory approach to a consistent and meaningful process.
7. Develop a shared, meaningful approach to co-production with providers for use in further work to be completed during CQC’s ongoing recovery programme.
8. Re-introduce a single point of contact/named inspector for providers
9. Train inspectors, with the involvement of care providers, to understand and respect each type of care service and the people that they support.
10. Establish an independent body to mediate all complaints and challenge processes.
    • Ensure that this is fully accessible and able to support smaller providers who may not have the same level of resource to commit to these processes.
11. Ensure that all changes in regulatory approach thus far and in future are effectively communicated to all inspectors to reduce inconsistencies in implementation. Communications to providers about changes expected at CQC should be accompanied by achievable timescales for completion.