The CQC have today outlined their strategy to change the way they regulate, with the aim of improving care-for-all. The CQC's objectives will no doubt be supported by all, but todays launch failed to provide any answers as to what it will mean in practice and will leave many thinking that at best the strategy still requires improvement.
The CQC promise to listen to the voices of those using care services and to focus on what is important to people and communities. There is also an intention to accelerate improvement by supporting providers to address gaps in quality, encouraging a culture of learning and promoting innovation.
The CQC propose to drive those changes using smarter regulation and promoting safety through learning. How that is done will be critical to whether the positive aims of the strategy can be achieved. The CQC have made clear that they intend to take a more dynamic and flexible approach to regulation, moving away from a fixed schedule of in service inspection towards a more targeted and focused approach responding to the services perceived to pose the greatest risk.
Those who have been subject to inspection in recent months will already have seen a similar approach, with remote inspections focusing on a small number of domains, most often 'safe' and 'well led'. Despite promises at the strategy launch today to take a well-rounded and balanced view, the experience of providers has been of a blinkered approach seeking only evidence to support the concerns raised, rather than to objectively assess whether those concerns are valid. While it is right that poor practice is called out and addressed, failing to provide a fair and well-balanced view, risks undermining any confidence providers have in the CQC and makes it difficult for those seeking support to take a fully informed view.
In the same way, despite the assurance that providers will be encouraged to promote a culture of learning from errors, in too many cases we have seen no real distinction between providers who have identified, reported and responded to problems and those who have made no effective response. That approach does little to encourage the open and transparent culture the CQC want to promote.
While the CQC are right to focus on safety and devote resources to areas of greatest risk, they must keep in mind the fundamental role of a regulator to act fairly. Fairness will be essential if they are to regain the trust of providers, who may question what if any support the CQC has provided during the pandemic. Fairness is also essential if those using care services are to be given the information they need to make informed choices. The CQC will only be able to rebuild confidence in their role as a regulator if they can demonstrate in practice that their new approach to inspection and rating is as clear, open and transparent as the services they seek to promote.
Providers will need to carefully consider how to proactively prepare for the new regulatory regime. As I outlined in an earlier article considering the implications of the CQC's consultation, it is critical that care providers carry out in-depth assessments of their own services to identify areas for improvement.
Embracing a proactive approach to complaints should enable providers to find a problem before the CQC, and take the appropriate steps to address it.
They should also consider building up compelling evidence and data covering all aspects of their service. Should a care provider believe that a rating has been made unfairly under the new system, clear evidence of high-quality care and positive feedback may support a challenge to the CQC’s approach – encouraging the CQC to assess a provider’s service as a whole.
This new strategy strengthens our commitment to deliver our purpose: to ensure health and care services provide people with safe, effective, compassionate, high-quality care and to encourage those services to improve.