The Care Quality Commission (CQC) is moving to a transitional regulatory approach from September onwards, having focused on its Emergency Support Framework (ESF) for many months during the COVID-19 pandemic.
It has confirmed that, whilst it is unlikely that it will return to its published frequency of inspection for some time, it aims to contact every social care provider by the end of March 2021.
This ‘contact’ CQC intends to make may involve an ESF conversation, inspection, and or an infection prevention and control (IPC) thematic review. Inspections are to be prioritised based on risk and CQC will make unannounced inspections where intelligence suggests that the people using a service are at immediate risk. CQC’s understanding of risk will be dynamic and based on feedback from the public, families and carers, whistle-blower concerns, safeguarding alerts, information from stakeholders and outcomes of ESF conversations.
CQC suggests that the scope will be widened to include inspection of services where it has evidence that the care needs to be improved more generally. However, it is unclear how quickly these inspections will be rolled out in light of rising infection rates.
The purpose of CQC’s risk assessment process is twofold: to seek to understand the service, and to inform decisions regarding the safest way to inspect. The assessment will include a call with the provider to discuss the environment.
CQC has made clear that it wishes to minimise time spent with providers and therefore will complete what planning and information gathering it can before the inspection. This is likely to involve requesting documentary evidence, arranging calls with staff, relatives and people using the service and exploring the layout of the service to plan routes to minimise contact.
Where CQC considers that inspections should be unannounced, inspectors may call providers from the car park to assess the COVID-19 situation at the home before proceeding.
Government alert levels, wider context and knowledge (for example issues and risks associated with the particular subsector and local or regional factors) will also inform CQC’s approach.
CQC has confirmed that on-site activity where local lockdowns have been imposed will only take place in exceptional circumstances.
Areas of interest
An obvious area for attention will be infection prevention and control steps taken by providers. CQC’s information-gathering tool for inspectors in relation to IPC reviews can be accessed via their website. This includes considerations as follows:
- Are all types of visitors prevented from catching and spreading infection?
- Are shielding and social distancing complied with?
- Are people admitted into the service safely?
- Does the service use PPE effectively to safeguard staff and people using services?
- Is there adequate access and take-up of testing for staff and people using services?
- Does the layout of premises, use of space and hygiene practice promote safety?
- Do staff training, practices and deployment show the service can prevent and/or manage outbreaks?
- Is IPC policy up-to-date and implemented effectively to prevent and control infection?
Other mandatory questions relate to the provider’s understanding of where to seek advice and whether appropriate measures are in place for those who are considered the most clinically vulnerable and those at increased risk due to protected characteristics.
Policies dealing with visiting arrangements are also likely to be scrutinised carefully, not least in relation to end of life care. Providers’ approach to balancing risks to safety and quality of life considerations has arguably never been more difficult, so, as with many of the key decisions taken throughout the pandemic, these will need to be properly articulated, with clear reference to the appropriate ethical framework.
What to do now
It might be useful for providers to take the time now to collate their answers to CQC’s infection control questions in readiness. They should also ensure that, at the very least, they have a clear and up-to-date response to the ESF. Providers would also be well advised to consider their safety, access and leadership arrangements and to formalise these in a protocol if this does not already exist, as Key Lines of Enquiry which touch upon these matters are to be specifically targeted.
The voice of staff members will be crucial to understanding quality of care on the frontline. In light of reports suggesting there has been a substantial increase in staff calls to CQC and trade unions, providers should consider the effectiveness of any feedback mechanisms in order to ensure staff concerns are understood and that support is offered as appropriate.
Finally, CQC is due to share its initial findings in relation to IPC best practice in September’s COVID-19 Insight report, with more detailed findings to follow in November’s edition. Providers should look out for these reports to learn from other services who either have remained COVID-free or managed outbreaks successfully.
Taking a reasonable approach
CQC has stated that it will seek to balance users’ experiences of care with making an accurate assessment of the quality of care, whilst at the same time minimising infection control risks and not unnecessarily adding pressure to the systems that providers have in place.
It is hoped that the regulator will take a reasonable, subjective approach to the presenting issues that each service will have faced, which of course may well have been very different across the country.
How are you preparing for CQC’s contact? Which areas of focus are you concentrating on? Share your knowledge by posting a comment on this article.