The webinar involved a number of CPA colleagues who were instrumental in working across the sector to produce the CPA’s inclusive and authoritative report, reviewing the CQC’s single assessment framework (SAF) and providing recommendations for its improvement. The webinar examined the report’s recommendations in more depth, bringing perspectives from the National Care Association via its Compliance Director, Amrit Sumal; the Homecare Association via Lynette Walker, Head of Quality and Compliance at Right at Home; from NCF, via Emma Lindblom, Head of Quality Improvement at MHA; and the Care Association Alliance via Louise Bestwick, Chief Executive Officer at Bradford Care Association. We also discussed how the CQC’s recovery plan can implement the recommendations in the coming months and we heard from James Bullion, CQC’s Interim Chief Inspector of Adult Social Care and Integrated Care, via recorded messages.
Webinar reflections
During the webinar, we explored the report’s key recommendations and dissected the shape and structure of the SAF to create a reduced set of quality statements (all specific numbers suggested by providers were under 20). These statements should be used consistently to assess providers during all routine inspections. We also highlighted the importance of working with the CQC to create service-level guidance for every quality statement including examples of what ‘Good’ and ‘Outstanding’ looks like for each service type.
In addition, we considered how to tackle poor assessment and inspection experiences care providers have reported to us. Possible solutions included ensuring inspection teams have read the Provider Information Return prior to inspection, giving care providers advance notice of inspection and sharing a plan for the assessment with them, including any evidence requests. We also expressed the critical importance of training CQC inspectors, with the involvement of care providers, to understand and respect each type of care service and the people that they support. The CQC restructure has resulted in a loss of social care expertise and understanding and we are eager to help the CQC workforce to rebuild this. It is also clear that there is an urgent need to re-introduce a single point of contact/named inspector for care providers.
Furthermore, we talked about how care providers want more confidence that evidence included in the CQC’s decision-making process has been corroborated rather than taken at face value. This would rebuild care providers’ trust in the inspection process as services would be viewed holistically, not focussed only on risk. We also pondered the need to re-write reports produced during the period between the SAF’s implementation and its stabilisation to a consistent and meaningful process. Looking ahead, we outlined how we might co-produce further work with care providers to support the CQC’s recovery. Moreover, we emphasised the importance of communication, ensuring that all regulatory changes – past, present and future – are effectively communicated to both CQC colleagues and the sector. A final recommendation discussed was the need to establish an independent body to mediate all CQC complaints and challenge processes.
Insightful data
During the webinar, we polled attendees on the urgency of the report’s recommendations. The recommendations remain valid and current; attendees told us that they want to see solutions in the next three months. Reflecting on the poll data, Emma Lindblom said, ‘The data reinforces the need for action as set out in the CPA’s report and the urgency with which these recommendations need to be addressed. With a significant number of inspections across the sector now ageing, CQC action to clarify guidance for providers, refine the number of quality statements and inspect against all areas would be a powerful first step to rebuild providers’ trust. Training for inspection colleagues and a named point of contact for providers would show CQC is listening to the sector, and wants to actively work to improve inspections, rather than just increase productivity. I would welcome formal responses to the CPA recommendations and timelines for achievement from the CQC.’
Amrit Sumal said, ‘Having looked at the data, I am pleased to see that the respondents align with our thinking in relation to what we perceive as the most urgent action to be taken. Reducing and simplifying the quality statements is key and a clear understanding of these quality statements along with what the CQC perceive to be a “Good” and “Outstanding” for each service type. Consistency in approach by the CQC is paramount. Trust can only be rebuilt within the sectors if there is transparency and communication. We now need to see these recommendations put into action and for the CQC to move forward and work together in partnership in achieving the recommendations.’
Next steps
Since our webinar, there has been some good progress to report. In early May, the CQC had a follow-up meeting with colleagues at the CPA to explore its proposed response to some of the recommendations, prior to issuing a formal response more publicly. There are a couple of recommendations which are more complicated to respond to in terms of legal and regulatory consideration. These are recommendation six and recommendation 10.
Recommendation six reads, ‘Re-writing 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.’ There are some technical regulatory issues here which mean it is likely that those services would need a re-inspection to enable a rewrite of the report. Recommendation 10 sought the establishment of an independent body to mediate all complaints and challenge processes – this would require a legal change and would likely take two-three years.
But there are recommendations that the CQC is keen to progress more speedily and it is exploring how the CPA might support a new work programme to facilitate this. There are two pieces of work that the CPA could work with the CQC to progress, whilst the CQC prepares its autumn consultation. The first of these could be work on a response to recommendation nine, ‘Train inspectors, with the involvement of care providers, to understand and respect each type of care service and the people that they support.’ The starting point for this could be a series of collaborative webinars for different provider types, facilitated by the CQC but directly involving providers and people with lived experience, focused on what they want the CQC and inspectors to know about their service type. The outcomes from these sessions would input into the CQC’s expanded initial inspector training programme and be offered to existing inspectors as an upskilling opportunity.
The second piece of work would respond to recommendation two, ‘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.’ This would be to support the CQC in creating a new ‘quality statement mapping tool’, which inspectors would use to complete inspections during the interim period before a new approach is implemented. This will state what ‘Good’ looks like under different quality statements and what evidence may be assessed under each one. This would aim to secure a clearer and more consistent assessment experience for providers as an interim approach during this waiting period prior to consultation. It will likely inform the final approach to assessment, but this cannot be guaranteed as the new approach will be heavily influenced by the outcomes of the autumn consultation.
Commenting on the CQC’s work to begin implementing the CPA’s recommendations, Richard Ayres, Social Care Advisor at Care England, said, ‘It is reassuring that the CQC have given consideration to the CPA voice which reflects a diverse adult social care voice, and we look forward to working collaboratively to not only improve on the current methodology but to help transform the inspection process into a far more positive experience for the breadth of care providers the CPA represents.’
Professor Vic Rayner OBE, Chair of the CPA, said, ‘There is a strong feeling amongst providers that the time for talk is over. The report CPA produced provided a level of granular detail about providers’ experience that CQC ignore at their peril. It is good to see plans evolving to move forward with some elements of the recommendations, but the fundamental need to improve the experience and confidence in the inspection regime needs to remain firmly at the top of the agenda for CQC.’
CMM and CPA webinar poll results
Click here to read the CPA’s report outlining recommendations to improve the effectiveness of the CQC’s SAF. Then, leave a comment on this feature or join the conversation to share your thoughts.
Liz Jones is Policy Director at the National Care Forum (NCF). Email: [email protected] X: @NCFCareForum