By April 2019, all NHS Trusts will have undergone a new style CQC inspection. This new inspection activity started in June 2017 and is gathering pace. The new style inspection reports are starting to be published on the CQC’s website and are attracting local and national press interest. So, what has changed from the previous inspection regime and what has stayed the same? Ian Cooper,a Partner with Capsticks, outlines 10 things you need to know about the CQC’s new inspection framework:
What has changed?
‘Well-led’ inspections
The new CQC inspections consist of two elements; a ‘well-led’ inspection and an inspection of at least one core service. The core services inspection will normally be unannounced and will be conducted before the ‘well-led’ inspection. The ‘well-led’ inspection will usually take place over two days and will consist of a number of 1:1 interviews, focus groups and divisional leadership meetings.
New Use of Resources inspections and reports
The CQC continues to inspect and rate the quality of care provided. However, for non-specialist acute Trusts, NHS Improvement will also undertake an inspection, lasting a day and concentrating on how efficiently and effectively NHS Trusts are using their resources to provide high quality, sustainable care. This will result in a separate ‘Use of Resources’ report and rating being published alongside the CQC’s quality report. At the moment, the use of resources rating is a stand-alone rating but, in time, it will be combined with the quality rating to produce the overall Trust rating. Use of Resources inspections and ratings will be rolled out beyond the pilot group to all NHS Trusts after 2019.
Inspection intervals
Each Trust will receive at least one new style inspection between June 2017 and Spring 2019. Thereafter, each NHS Trust will be subjected to an annual ‘well-led’ inspection plus an inspection of one or more core service. The CQC will choose which core services to inspect based primarily on the previous ratings the core services received. Those core services rated as ‘inadequate’ will be inspected every year. Core services rated as ‘requires improvement’ will be inspected at least every two years. The CQC will leave it a maximum of three and a half years to inspect those core services rated as ‘good’ and five years for those rated as ‘outstanding’. Therefore, regardless of what rating your Trust has, the CQC will be on site carrying out a ‘well-led’ inspection every year. This is a significant change from the previous regime.
New reporting format
The reports which will be published following a new style inspection will change. The main report will be a shorter inspection report; setting out the main findings and also the new ratings in each area (see point 5 below). This report will usually be in the region of 30 pages. The inspection report will be supplemented by an ‘evidence appendix’ which will run to 150+ pages and contain a significant amount of detail to underpin the judgements and ratings in the main report.
Mixing old and new ratings
The main report will contain a ratings table which will consist of a mixture of the new ratings arising from the latest inspection and the old ratings from the previous inspection (i.e. those areas not inspected this time round). These ‘new’ and ‘old’ ratings will aggregate up to produce the Trust’s new overall rating. This can be frustrating for those Trusts who think they have improved since the last time they were inspected as only a handful of core services will have the chance to demonstrate improvements to the CQC, whereas the others will be stuck with their previous rating until such time as they are re-inspected. It could therefore take a number of inspection cycles to improve an overall rating, unless a Trust can convince the CQC to carry out a ‘comprehensive’ inspection where all core services will be inspected.
Merged Trusts
The CQC has confirmed that when a Trust acquires or merges with another Trust then the ratings of both Trusts will not be aggregated for up to two years. This may offer some comfort to Trusts looking to acquire struggling organisations or services in order to improve the quality and safety of care.
New KLOE
The CQC will continue to inspect against the five key questions of safe, effective, caring, responsive and well-led but will use a slightly tweaked set of KLOE and prompts which will now apply to any registered provider delivering healthcare services (all NHS Trusts, GP practices, GP out-of-hours and NHS 111 services).
What has stayed the same?
The fundamental standards
The legal standards of care have not changed. The ‘Fundamental Standards’ are exactly the same as they were before and ultimately, these represent the legal standards for which Trusts are held to account.
Enforcement
The enforcement regime which the CQC will follow in the event of any breaches of the Fundamental Standards has stayed the same with the CQC using a range of Requirement Notices, Warning Notices, Conditions, Special Measures, Penalty Notices and criminal prosecutions to protect service users and to hold providers to account.
Factual accuracy process
The process for ensuring the factual accuracy of the draft report remains the same as do the more formal routes of ratings reviews and complaints to the CQC. The draft report will include draft ratings and as the CQC’s guidance confirms, if the CQC “makes changes as a result of factual accuracy comments, this may result in a change to one or more rating."
[Capsticks is a specialist health and social care firm, based in Birmingham, Leeds, London and Winchester. Capsticks has helped over 80 NHS Trusts in their dealings with the CQC with the aim of improving outcomes for patients, staff and the public.]
