More than six months on – what does the CQC inspection strategy mean for the health and social care sector?

More than six months on from the launch of the new CQC inspection strategy for the health and social care sector, how is it working out in practice? And what does it mean for Registered Providers who are subject to CQC inspections and its grading regime?

The CQC says the new strategy is about changing how it regulates health and social care providers “to improve care for everyone” with greater emphasis on the lived experience of service users. Who could argue with that? And who wouldn’t welcome the general principle of “smarter regulation” or “accelerating improvement” through the sharing of best practice?

Regulation, it says, will be “more relevant to the way care is now delivered, more flexible to manage risk and uncertainty, and will enable us to respond in a quicker and more proportionate way as the health and care environment continues to evolve.” So far, so good.

Registered providers I speak to, who run care homes or provide domiciliary care, are still making sense of the new strategy and what it means for them. But while most welcome the strategy’s ambitions, they still want more detail. Not all have had experience yet of the new inspection regime in practice and most are still considering what it will mean for their services. it.

The general direction of travel though, signalled by the CQC in the strategy, is clear. Crucially, fewer inspections will now be carried out in person, so it’s less likely CQC inspectors will in future arrive at your care home to go through your reporting documents. Instead, these documents will probably be asked for digitally in the future, with inspection then carried out remotely.

Going forward, ‘in person’ inspections will also be more driven by risk - so if complaints or concerns have been raised through staff or residents or their families, levels of safeguarding or statutory notifications have increased. The risk of that, of course, is that only bad providers will end up being inspected.

So how do providers need to adapt to the changing focus of CQC regulation?  Well, in some respects, my advice is the same as it always has been: delivering good quality care should be your priority. And you should do this not to keep the regulator happy, but because it’s the right thing to do. Don’t wait for an inspection to identify service failures or improvements– ensure you have robust internal processes to monitor the quality of care you deliver and seek ways in which to constantly improve it.

Data gathering and intelligence also needs to be given a lot more serious consideration. This is more likely now to be used to trigger an inspection so it’s vital that systems for collating and storing data are fit for purpose. You should be able to access that data - and provide it to the regulator - in a timely fashion.

There is still a need for further clarity from the regulator on exactly what they are looking for - and it needs to spell out what it means by a requirement for “high quality data”. The strategy is still a work in progress in some respects and providers should note that there are opportunities for them to influence how the strategy develops. I personally would like to see the regulator demonstrate more consistency on what high quality looks like.

High quality data, I think, is dependent on having an open and honest culture within your organisation. Do your systems for collating the views of residents, families and staff really encourage meaningful feedback? Do you really know what they think about your service? So perhaps think about ways feedback can be obtained anonymously or privately in some way.

Don’t be afraid of constructive criticism either - that’s how we all learn. All too often I hear people say they welcome complaints - but do we really welcome complaints?

Drawing data from this wide variety of sources - residents, their relatives or friends, staff and commissioners / local authorities – is crucial. You need a broad evidence base which takes a broad view of your service. Ask yourself: are we collating the right data and do we understand what it is telling us? Is it properly highlighting what we are doing well and where there is room for improvement? But don’t always be thinking about jumping through the regulator’s hoops: again, improving your service should be your primary motivation.

Ask your stakeholders the right questions as well. Break your service down into specific elements - food, care, accommodation, activities - and ask about each of these. For example, ask people do they feel they have choice?, and do they get privacy when they want it? And why not even take them to see other similar provision in your local area to give them a sense of what other providers offer?

On balance, the new CQC strategy is to be welcomed in my view. It puts the focus rightly on the service user and their experience of care. For providers, there will be encouragement to be open and honest, and the emphasis will be on supporting service improvement. It’s also right that the CQC’s resources should be targeted on those who are falling short.

In the past, stakeholders would often write to the CQC and might come away feeling nothing had happened; that they hadn’t been listened to. With the new strategy I’m optimistic that can change. Elements of the new process are still not quite there in my view - but if we get this right we have a potential opportunity to deliver the real improvements the sector needs. The lives of many of our most vulnerable citizens depend on it.