CQC and system level regulation

Following the publication of the Department’s White Paper on health and care, the Parliamentary Health and Social Care Committee have been examining the proposals in Integration and Innovation: working together to improve health and social care.

The core change proposed in the White Paper is the replacement of Clinical Commissioning Groups with Integrated Care Systems who will be put on a statutory footing. However the White Paper proposals do not include regulatory changes to allow the Care Quality Commission to rate ICSs. This has therefore raised concerns around accountability and how patients will know whether their local NHS, the local Integrated Care System, is doing a good job or not.

Last week, the Secretary of State told the Commons that the Care Quality Commission would have a “crucial role” in that and said: “I think that it is vital that the CQC has a similar role when comes to ICSs.”

This is clearly a view supported by other experts, including Sir Robert Francis, Healthwatch England chair who in giving evidence to the Committee said:

“…there should be some form of oversight [of ICSs], probably by the Care Quality Commission, of the system. The value of that has already been demonstrated by the system reviews that the Secretary of State commissions from time to time… As far as a rating is concerned, we need to consider who the audience is for that rating….It does not affect patient choice in quite the same way as a provider rating does, but it may be a way of explaining to the public how their system is doing.”

It remains to be seen whether we are likely to see the CQC rate ICSs in the same way that it rates hospitals, GP surgeries and care homes by having the Ofsted rating system and whether it would provide that outward accountability and transparency health policy experts say is required.

If we were to move to Ofsted ratings, it will be important to ensure that the system works and happens in a light touch way, and does not lead to additional bureaucracy.

CQC strategy and system working

Last week saw the regulator’s eight week consultation on its strategy come to a close.

The CQC’s proposed strategy for the next five years does set out an ambition to adapt its approach to system working and to review how different parts of the health and care system work together to provide joined-up care. This shift to assessing the whole system does reflect the White Paper proposals on integration and collaboration and the move to place based health and social care.

It is clear that the CQC has identified a need to transform and ensure its regulatory model is relevant and fit for purpose in what is an evolving system. The CQC plan to publish their new strategy and begin implementation in May 2021.


We will have to wait and see what, if any, changes are included in the Bill to deal with the issues around the regulatory oversight and assurance of ICSs – and the CQC’s new strategy.

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