As noted in our first alert, the new CQC Single Assessment Framework (“SAF”) has a number of features which, in theory, providers should welcome as part of the move towards smarter regulation.  However, the roll out of CQC’s guidance on how it will assess, score and rate services under the SAF raises concerns that some of the potential benefits of the new system may be undermined by the practical application of the framework. 

A key issue is whether the new assessment is an up to date reflection of a service run by a registered provider.

For each Quality Statement, CQC has set out key evidence categories.  These specify the types of evidence which CQC needs to have gathered, as a minimum, in order to be able to award a score to that Quality Statement.  As mentioned, it is hoped that this will improve triangulation and guard against CQC being overly reliant on a single source of information

However, CQC’s guidance states that it will have the flexibility to:

“collect and review evidence in some categories more often than others. For example, we may collect evidence of people’s experiences more often than evidence about processes”[1]

This is further emphasised where CQC states:

“It is only the first assessment of our new approach, and for services newly registering with us, that we’ll look at every key evidence category. For future assessments we may review evidence just in particular categories.”[2]

It seems, therefore, that, once CQC has initially awarded a score to each of the key evidence categories for a particular Quality Statement, its subsequent assessments (and scoring) of that Quality Statement may be based on a ‘mix and match’ approach of some up to date evidence (eg of service users’ experiences) alongside some old evidence in other categories (eg CQC’s on-site observation).  Whilst this may be a pragmatic approach, it does raise the question of whether the older pieces of evidence CQC is relying on are still reflective of the current position.  It may not be realistic to expect CQC proactively to gather evidence in each category each time it assesses a Quality Statement.  However, if there is more up to date evidence in some of the key evidence categories which CQC is not planning on including in its latest assessment for a particular Quality Statement, will providers be able to ask CQC to take this into account?  In this respect, it is a concern that  CQC’s guidance states:  

“For now, providers do not need to submit evidence to us proactively. We will ask you for anything we need.”[3]

Although CQC states that providers do no “need” to submit evidence proactively, the question remains whether, if providers do submit such evidence, will CQC take it into account?  There is a concern therefore, that, although assessments of services under the SAF may be updated more frequently, they may not truly reflect the up to date position at a service.

We stress that this concern is based on our understanding of the current CQC guidance, which is very brief on this issue.  We hope that this concern is unmerited.  However, it would be helpful if CQC could provide further clarification of its approach in this respect in order to allay such fears.

If you wish to discuss any issues relating to CQC’s new Single Assessment Framework, please contact:

Carlton Sadler or Siwan Griffiths

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