No more boots on the ground

As healthcare providers will be aware, the CQC is rolling out its new ‘single assessment framework’. The practical detail of how this will work is not entirely clear and no doubt the CQC will need to refine the processes over the coming months.

However, what is clear is that there is a shift away from in person inspections and a move towards evidence collection and reliance on third party intelligence. CQC is changing its process from “inspection” to “assessment” and away from its ‘boots on the ground’ approach.

Quality statements and evidence categories

The CQC is replacing its current ‘Key Lines of Enquiry’ with 34 ‘Quality Statements’ or QS.  These QS relate to areas across the five key questions of safe, effective, responsive, caring and well-led.

In order to assess services against these QS, the CQC has set out six categories of evidence that it will assess, and each evidence category will be scored from 1 to 4.

The six evidence categories are:

  1. People’s experiences of health and care services
  2. Feedback from staff and leaders
  3. Feedback from partners
  4. Observation
  5. Processes
  6. Outcomes

Observation is the fourth evidence category in the CQC’s new inspection regime and includes both off-site and on-site observations.

It is clear from these evidence categories that the CQC is moving away from its traditional approach based on inspection of services on site, with only one category out of six being directly based on what CQC inspectors observe at a service.  The evidence category of “Observation” will however include off-site observations gathered from local Healthwatch and other partners and via the Experts by Experience programme. Where evidence from these other bodies is about the care environment, this will be included in “Observation” rather than the ‘Feedback’ categories.

The other five evidence categories all rely on non-observational evidence.

As a result, we expect physical inspections of services to take place only where there are concerns or where evidence gathering can only be done on site.

Impact on care homes

This new approach means care homes need to be more proactive in their approach to CQC regulation. Rather than responding to a CQC inspection which may take place once every two or three years, providers will need to proactively provide evidence to the CQC on an ongoing basis.  The idea behind this is to allow the CQC to provide a dynamic up to date assessment of risk and enable it to reassess service providers much more frequently than it does under the current inspection framework.

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