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CQC announces detail of new inspection strategy

As a result of COVID-19, routine inspections were suspended in March 2020. Since that time CQC has been adapting to the problems caused by this and reviewing the way they inspect. On 14 June 2021 CQC announced further changes to the way they monitor regulated services by issuing the following statement:

“The developments we’re announcing today carry on the progress in how we monitor services in three key areas by:

  • improving our ability to monitor risk to help us be more targeted in our regulatory activity
  • bringing information together in one place for inspection teams, presented in a way that supports inspectors with their decision making
  • testing elements of how we want to work in the future, including how we provide a more up-to-date view of risk for people who use services.

Developing our monitoring approach

We want to build on our learning over the last year to make changes in our ability to monitor services. We’ll use [a] pilot to help improve the process further before rolling out to all services.

We’ll carry out regular reviews that will help support our ability to monitor risk. Where the information we have does not find evidence that tells us we need to re-assess the rating or quality at a service, we will publish a short statement on the profile page on our website for these services. This will inform the public and people who use services, that this review has taken place and that we had no concerns based on the information we held at that time. We will also communicate this with the provider by email prior to the public statement being published.

We currently plan to carry out this review each month. This will enable our teams to target their resources where they are most needed.

Responding to risk

In cases where the information review indicates that we may need to re-assess a rating or the quality of care, our inspectors may want to gather more evidence. For services where we believe people may be at an increased risk of poor-quality care, we may undertake an immediate on-site inspection, and this may happen at any time. In these cases, we may update the rating for a service.

Inspectors’ judgement will still be at the heart of our approach to inspection, the improved access to information will allow inspection teams to act quickly using their judgement, supported by our quality assurance mechanisms, where other sources of information indicate greater levels of risk elsewhere.

To ensure we’re making consistent and robust decisions we’ll also carry out some sampling of services by carrying out an inspection. In this way, we’ll be able to check that our monitoring activity is consistent with our inspectors’ findings when they gather evidence either by telephone or by making an on-site visit.”

Protocol for health and social care regulators to share information that may indicate risks to people using services, their carers, families or professionals.

The CQC has also announced a protocol developed under the governance of the Health and Social Care Regulators Forum to allow regulators to share information.

The purpose of the protocol is said to be “to provide a clearly defined mechanism for organisations which have a role in the quality and safety of care provision, to share information that may indicate risks to people who use services, their carers, families or professionals. No piece of information is too small to invoke the protocol.”

The announcement goes on to explain the remit and purpose of the protocol as follows:

“Information [to be shared] might include, but is not limited to:

  • situations that may not be seen as an emergency, but which may indicate future risks
  • cultural issues within health and social care settings (including educational environments) that would not necessarily be raised through alternative formal systems

The objective of the protocol is to be flexible and empowering, supporting regulators to understand how they can share information. This protocol is designed to work alongside protocols that already exist. However, it is specifically aimed at helping staff across the signatory organisations to make decisions about when to escalate information of concern with one or more organisations. It is not intended to work against good working relationships and existing informal mechanisms that already exist, but to strengthen and encourage good practice. Nor is it intended to override the autonomy of existing organisations.

Principles of the protocol

The following principles – which underpin the protocol – have been agreed across all organisations acting as signatories:

  • The organisations involved should work to model an open culture in which staff can speak up about concerns
  • The organisations involved should be transparent about how the protocol is used, while maintaining confidentiality of content (in all directions, including the National Quality Board, providers, public, registrants)
  • The organisations are explicit about confidentiality agreements and parameters (including working with information shared by third parties)
  • The organisations involved shall maintain and respect each individual organisation’s executive autonomy
  • The protocol must work within the law, including any restrictions on information sharing that are included in each signatory’s statutory role
  • The protocol should be short and simple, with a focus on feasibility
  • The protocol will be developed through a collaborative, partnership approach between organisations
  • No issue will be too small for an organisation to consider using the protocol
  • The model developed should be linked to other tools in the system, such as the Quality Risk Profiling Tool and existing Memoranda of Understanding.”

The full protocol is available here.


Disclaimer

This briefing is for guidance purposes only. RadcliffesLeBrasseur LLP accepts no responsibility or liability whatsoever for any action taken or not taken in relation to this note and recommends that appropriate legal advice be taken having regard to a client's own particular circumstances.

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