Amanda Narkiewicz, healthcare regulatory partner at Mills & Reeve, explains how regulated providers can prepare for the forthcoming Care Quality Commission monitoring and inspection changes due in the autumn

The Care Quality Commission confirmed in its summer update how and when it would be introducing its new portal and regulatory approach. Registered providers operating in the South of England are the first cohort to be assessed under the new inspection framework.

From November, the CQC’s decision to assess providers using the Single Assessment Framework (SAF) will be based on the ‘level of risk’ and so not all providers will have an immediate assessment using the new framework. However, providers operating outside the southern counties will be monitored, assessed and rated under the current system. The CQC will make announcements about other regions in due course but it is expected that by March next year the inspection regime will be fully rolled out across England.

Changing the mindset
The SAF reflects a fundamental shift in how the CQC will inspect and assess the quality and performance of service providers, but it does also require a shift in a service provider’s approach to future inspections. Getting your approach right now will be hugely valuable for your staff and business.

We have been working with several providers to support them with getting ready for the new SAF as the CQC continues to update some of the evidence category descriptions and provide further information on how it will assess quality and performance, including the introduction of new rating limiters linked to scores for the quality statements under each question. Providers will need to focus on all the quality statements to avoid the new rating limiters within each key question.

The regulator intends to use its ‘rules and limiters’ to “make sure that any areas of poor quality are not hidden”.

According to the CQC, if the key question score is within the:
• Good range, but there is a score of one for one or more quality statement scores, the rating is limited to Requires Improvement
• Outstanding range but there is a score of one or two for one or more quality statement scores, the rating is limited to Good.

Providers will therefore need to focus on all the quality statements to ensure they maximise their rating.

Getting ahead
We have facilitated several workshops on SAF to support operational leads to understand what is expected under the new framework. Our approach has been to work through each of the five key questions (Safe, Effective, Caring, Responsive and Well-led) and for each question we have looked at the corresponding quality statements, also known as ‘we statements’ which describe what good care looks like (these each link to the current Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 and CQC guidance) and how to evidence. We also discuss the examples of policies and resources that help providers gather and document their evidence.

Our step-by-step approach has enabled providers to identify gaps and action points for operational leads to focus on. Each workshop is designed to ensure that for each quality statement, providers can assess their current level of compliance, develop a continuous improvement action plan and above all, evidence it – and that includes those magic moments that demonstrate positive feedback. Each workshop would then be summarised in tabular format and updated as key actions are achieved. As part of our new SAF preparation checklist, we also share worked examples of how a rating decision is reached and how this would look with the new rating limiters.

We believe that our approach supports the CQC shifting its focus to place a stronger emphasis on assessment over inspection and conduct more continuous assessments based on evidence.

Get in touch with Amanda Narkiewicz if you’d like to find out about Mills & Reeve’s compliance support services and how we can support your care provider transition to the new assessment framework. Call 01223 222 267.