CQC Consultation - The New Assessment Framework

Part 2 of the consultation – 'The new assessment framework' proposes a raft of changes to CQC's assessment framework which will impact upon all providers (independent health and social care and NHS) alike. 

CQC state that the proposals are not intended to "raise the bar" or make it more difficult for providers to achieve a 'Good' or 'Outstanding' rating.  Instead, they state the aim is to simplify the assessment framework by closely aligning the frameworks for all sectors and enabling providers to understand more easily what is expected of them. 

The upshot of this is that CQC propose to move from its current 11 sets of Key Lines of Enquiry ("KLOEs") to just two:  a single set of KLOEs for healthcare services, and another set for adult social care.  Whilst this may simplify matters (by having a single set of expectations) for providers who provide a range of different services, providers may wish to consider the proposed new frameworks to ensure they are fit for purpose for all services and that any important differentiations between previous different sets of KLOEs have not been lost;  this was, of course, one of the criticisms of previous regulatory regimes in that they sought to impose a 'one size fits all' system.

It will be important for providers to review the Consultation proposals in detail.  However, we set out some of the highlights below:

Hospices

CQC confirm that from 2017/18, after they have completed the first round of inspections for hospices under their current model, they will begin assessing hospices under the healthcare assessment framework, rather than as an adult social care service.  Hospices will therefore fall under the responsibility of the Chief Inspector of Hospitals.

The five key questions

These will remain the same.  However, although some new KLOEs and prompts are being introduced (see below), the major proposed structural changes within the five key questions themselves are:

• Consent and Mental Capacity Act – CQC are proposing to move their assessment of these issues to be dealt with under the 'Responsive' key question, as opposed to 'Effective' as has been the case to date.
• Responsive – CQC are changing the focus of the 'Responsive' key question so as to focus solely on the way services respond to service users' specific needs. In future, it is proposed that the ability of a provider to respond to wider, population, needs will be considered under the 'Well-led' domain.
• 'Well-led' - for healthcare providers, the 'Well-led' domain has been extended to include eight KLOEs (compared to five for adult social care providers). It appears, that CQC is proposing a more detailed assessment of 'Well-led', especially amongst larger providers.  Although the driver for this appears to be CQC's joint work with NHS Improvement in relation to NHS trusts, it seems the extended 'Well-led' framework will also apply to independent sector healthcare providers.

New and strengthened themes

The Consultation proposes to introduce a range of new KLOEs and prompts (which differ between healthcare and social care providers) focusing on certain themes CQC will have particular regard to in its future assessments.  Details of the individual KLOEs and prompts are set out in the annexes to the consultation (for healthcare services and adult social care services), but the themes they address are:

• System leadership, integration and information-sharing
• Information governance and data security
• Use of Technology
• Medicines
• End of life care

In due course, providers will need to ensure that their own quality assurance systems are amended to reflect the new assessment frameworks, and particularly to pick up on the new KLOEs and priorities which CQC are introducing to their assessments.

Ratings

The annexes to the consultation also helpfully break down the key ratings characteristics to provide a description of what constitutes 'Good' (and each of the other ratings) for each KLOE, rather than just at key question level.  This might be helpful as it may lead to greater clarity and consistency in CQC's translation of factual findings into ratings, and may also be useful for providers when challenging draft inspection reports.

Timing

It is proposed that the new frameworks will be phased in across the sector as follows:

• Healthcare services (NHS and independent) – from April 2017
• Adult social care services – from July 2017
• Primary medical services – from October 2017
• Primary dental services – from April 2018]

Conclusion:

It is important that providers review the proposed changes set out in the consultation thoroughly, consider what they will mean for them and respond to have their say upon the future regulatory landscape.  The deadline for responses to the consultation is 14 February 2017.     

If you wish to discuss the consultation and what it means for you, please contact: Carlton Sadler