After months of consultation the CQC has at last published guidance to providers on how it monitors, inspects and regulates adult social care services. The new guidance I believe represents a major shift in the regulators approach to inspection. The guidance ‘How CQC monitors, inspects and regulates adult social care services’ November 2017, suggests a movement away from the frequency of inspection to more reliance upon information that is returned by providers.
Insight
CQC will use Insight to monitor potential changes to the quality of care. The CQC Insight system is designed to bring together information about a service in one place, and analyse it. This helps the regulator to decide what, where and when to inspect and provides analysis to support the evidence in inspection reports.
To monitor changes in the quality of care, inspectors will check CQC Insight regularly. If it suggests that the quality of care in a service has improved or declined, inspectors may follow this up between inspections or ask providers to give them further information or explain the reasons for the change. They may also decide to re-inspect the service, if there are significant concerns, or may carry out a focused inspection.
Provider information collection (PIC)
The provider information collection (PIC) allows social care providers to submit up-to-date information about the quality of care their service provides at a location. The PIC builds on and replaces the previous provider information return (PIR). PIC information is reviewed and analysed before being passed to inspectors as part of the regular updates they receive about the services they inspect.
Providers should be in no doubt of the importance that CQC place upon the provider information collection and must update the PIC at least annually. If they do not do so, their rating for the well-led key question will be no better than requires improvement at the next inspection.
Inspection
The biggest change to inspection is the frequency in which it is carried out.
A service will have a comprehensive inspection at the following frequencies:
Services rated as good and outstanding – normally within 30 months of the last comprehensive inspection report being published.
Services rated as requires improvement – normally within 12 months of the last comprehensive inspection report being published.
Services rated as inadequate – normally within 6 months of the last comprehensive inspection report being published.
Newly registered services and those no longer dormant – the first comprehensive inspection will normally be scheduled between 6 to 12 months from the date of registration.
Comprehensive Inspections
Comprehensive inspections take an in-depth and holistic view across the whole service. Inspectors will continue to look at all five key questions to consider if the service is safe, effective, caring, responsive and well-led. They will give a rating of outstanding, good, requires improvement or inadequate for each key question, as well as an overall rating for the service.
I guess that many of those services who are rated as outstanding or good will welcome the new frequency of inspections. Given they will only receive a comprehensive inspection every 30 months, providing there are no concerns with their provider information return. As a former principal inspector, I have real professional concerns about this length of time between inspections. Figures show that the duration of time the average service user lives in care home does not normally exceed much more than 2 years. This in effect means that there will be vast changes in the needs of service users over this period of time and a reliance on documentation to evaluate their quality of care. Nor does the approach take into account staff recruitment difficulties, and staffing changes.
Given that only 2% of Care services are rated as outstanding, it seems that fewer inspections are less likely to give the general public more confidence in the care sector. I think the CQC is in danger of forgetting that a service does just have to achieve quality but has to demonstrate how it can maintain it.
Summary
The CQC new guidance for providers of adult social care services shows a major shift from the importance of on- site inspection to a reliance on information gathered from providers. I remain to be convinced that fewer inspections will lead to improvement in the quality of services, given the ever-present changing social dynamic of a care service. CQC will claim that they want to place their focus on services that are underperforming. However, a question that is bound to be asked is: “will the new inspection regime be of benefit to providers and service users, or has it come about through a tightening of the resources that they now have available”?
Albert Cook, BA, MA & Fellow Charted Quality Institute Managing Director Bettal Quality Consultancy