Care Quality Commission – Update on the Single Assessment Framework

Following the identification of failings in Dr Penny Dash’s interim report as part of the Cabinet Office review of the Care Quality Commission in July, CQC acknowledged these concerns and indicated it would be undertaking various steps to improve its performance across a wide range of areas.

Pending publication of Dr Dash‘s final report, which is anticipated later this month, CQC last week published an update providing some (albeit brief) further information on the steps it is taking to rebuild trust in the organisation.

One of the major concerns identified in Dr Dash’s report, and shared widely across the sector, related to the methodology for scoring and rating services during assessments under the Single Assessment Framework (“SAF”).  In this respect, CQC’s Update announces that it is making changes to the SAF and states:

“We will be scoring at quality statement and rating at key question level. Assessments will still evaluate evidence categories to reach a quality statement score but we will not score evidence categories. We will apply professional judgement to ensure it is a complete picture and the quality statement scoring is correct. This will allow us to assess and inspect more services while ensuring our ratings are robust. This will also allow us to produce better reports that are clearer about our judgements and ratings.”

This Update is very brief but, on the face of it, raises a number of further issues and concerns:

• although it is clear that CQC will not be scoring findings at an Evidence Category level, it is not clear whether CQC is still intending to gather evidence in each of the key Evidence Categories for the Quality Statements being assessed.  If not, this might cause some concern in terms of whether findings on assessments will be triangulated.
• by moving away from scoring Evidence Categories, CQC seem to be moving towards a system where the score awarded at the Quality Statement level will involve a greater degree of discretion (as opposed to being arrived at mathematically). In the absence of clear guidance as to what should be scored as a ‘1’, ‘2’, ‘3’, or ‘4’, would appear to create an increased risk of subjectivity and inconsistency in the scores awarded at Quality Statement level and, in turn, in the ratings which will be awarded at Key Question level.  Hopefully, it is the case that, alongside this new approach CQC will be providing guidance (for both its own staff and providers) as to how findings in relation to each of the individual Quality Statements should be scored - in a similar fashion to the Ratings Characteristics guidance under its previous regulatory regime.  However, it is a concern that there is no reference to any such guidance within CQC’s Update on the immediate steps it is taking.

We hope that further information from CQC regarding steps it is taking to ensure consistency of scoring of Quality Statements (and consequently ratings) will be forthcoming shortly and we look forward to hearing more on this as Dr Dash’s report - and the response to it - are published in the near future.

If you wish to discuss any of the issues above, please contact Carlton Sadler or Siwan Griffiths.