quality management systems (policies and procedures) to the care sector, and our systems include more than 300 documents. One of our customers recently became alarmed when an inspector suggested that she should think about writing her own policies and procedures. As a former principal inspector, sometimes I wonder which planet some of the inspectors come from. I am all for managers customising our documents to address their culture and values, but if Bettal is doing its job correctly we will be providing managers with documentation based upon best practice and compliance to the Fundamental Standards.
There are two issues here. Firstly, does the manager have the time to write their own policies and procedures. Secondly, is it necessary if the documentation is shown to deliver quality services for service users and compliance to the Fundamental Standards.
Returning to the introduction of the new KLOES and inspections. CQC’s inspection teams will use the new updated framework to assess adult social care services, using the new key lines of enquiry (KLOEs) and prompts where they are appropriate. This replaces the previous separate versions for different types of service, published in 2015.
The consultation process found that many of the KLOEs and prompts were duplicated. CQC have designed the new KLOES to simplify the process for organisations that provide more than one type of service. They have merged the two previous versions for residential and community care, added new content to strengthen specific areas and reflect current practice, and made some changes to the wording to improve and simplify the language to aid understanding. They have also aligned, as much as possible, the wording of the KLOEs and prompts between the two assessment frameworks for healthcare services and adult social care services. To help providers to update their own internal assessment and training materials, they have mapped the changes against the current frameworks and highlighted them in a separate document.
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CQC Principles
The consultation was based on a set of CQC principles which are designed to guide their approach to regulating in a changing landscape of care provision in the future, namely:
1.0 We will always take action to protect and promote the health and well-being of people using services where we find poor care.
2.0 We will hold to account those responsible for the quality and safety of care.
3.0 We will be proportionate, and will take into account how each organisation is structured and its track record to determine when and how to inspect.
4.0 We will align our inspection process where possible, to minimise complexity for providers that deliver more than one type of service.
5.0 We will be transparent about our approach and about how we make regulatory decisions.
6.0 We will not penalise providers that have taken over poor services because they want to improve them.
7.0 We will deliver a comparable assessment for each type of service, regardless of whether it is inspected on its own or as part of a complex provider.
8.0 We will rate and report in a way that is meaningful to the public, people using services and providers.
9.0 We will bring together inspectors who have specialist knowledge of different sectors to inspect jointly, where this is most appropriate for the provider.
Revision of characteristics that inform adult social care ratings
CQC have revised the characteristics that inform adult social care ratings to clarify how they relate to each of the KLOEs and associated prompts and to reflect what they have learned over the last two years of inspections under the new approach. They claim that this does not represent a shift in terms of the ‘bar’ that providers must reach for each rating. But it does mean that they can adopt a more a more targeted, responsive and collaborative approach and be clearer on what good and outstanding practice looks like.
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