28.10.15
Providers could self-regulate under new CQC inspection strategy
Proposed changes to the way the CQC works outlined in its 2016-21 strategy could include moving to a co-regulation regime, where providers proactively assess their own quality of care and report back on changes since previous inspections.
The option is among a number of changes that the commission put forward for consideration to change the way it inspects and regulates health and adult social care providers in England to increase its efficiency, lately revealed to be waning.
It wants feedback from providers and service users on its new ideas.
Alongside the new approaches, the report outlining proposed changes also sets out the case for developing an assessment of how NHS hospitals use their resources. This is being developed at the government’s request and could potentially sit alongside CQC’s rating system.
David Behan, its chief executive, said: “Our next strategy will set out the case for developing our approach – building on the strong foundations we now have in place. We will make our current model more efficient and effective by being more risk-based and proportionate; we will also look at the quality of care in a geographical area and across pathways of care.
“Regulation alone cannot drive improvement but it has a crucial role to play alongside the role of commissioners, providers and professionals. This document sets out our thinking about how working with others can further contribute to the improvement of the quality and safety of health and care in England.”
The commission is encouraging feedback until 22 November ahead of a formal consultation on the strategy set for January 2016. The five-year strategy is expected to be published by April 2016.
Co-regulation
The co-regulation focus would place greater responsibility on providers to assess and share evidence of their own quality of care against the CQC’s key questions.
This could be further expanded by asking providers that have already been inspected under the CQC’s new approach to proactively report on any changes to the quality of care provided since their previous inspection.
The CQC would then compare this evidence with the monitoring data it holds about the provider, joined by other data including the views of service users, staff and local partners. It hopes the compounded information would help target activity to ensure it prioritises the right things during inspections.
But in a report outlining the four potential new ways of working, the commission guarantees that this approach does not mean it would rely solely on the information that providers give it without challenge.
The report said: “Co-regulation could encourage providers to develop their own systems and processes for understanding quality, which we know is an essential step in developing a culture of continuous improvement.
“While CQC must always act swiftly where risks emerge, it is providers who deliver improvements, and we want to encourage and support them to do so.”
Risk-based approach
Another option would see the regulator developing a more proportionate, risk-based regime to new registration applications and registration changes. For example, lower-risk changes to registrations, such as a high-performing GP practice group opening a new practice, would be handled in a more “streamlined” way.
But higher-risk changes, such as a new provider opening a new care home for people with learning disabilities, would be treated with “appropriate expertise”. This would include ensuring new models of care are registered in a fair way by using the “expert judgement” of ‘experts by experience’ and sector specialist inspectors.
The risk-based regime would see the CQC develop a more differentiated approach based on what it knows about the relative risks of different services and types of registration changes. The commission expects that it would strengthen the links between their approach and expectations at both registration and inspection.
It also plans to improve how information is gathered from registration to feed into later monitoring and inspection, as well as to make sure providers are clear on what is expected of them and what they need to do to register.
And in the diversifying NHS market, the CQC hopes this option will improve their approach to handling new models of care – including joint enterprises, vanguard projects and national collaborations.
Smarter monitoring
One of the last two options would hope to build on ‘CQC Insight’, a comprehensive surveillance model set out in the 2015-16 business plan that would combine numerical data with feedback from service users.
The CQC said the existing data is not yet robust enough across all sectors to be a reliable measure of quality without depending on inspections. As a result, it hopes to work with others to improve the data and develop a shared view of the most important quality and risk indicators in health and social care.
The commission would then be able to protect service users by acting when concerns are raised, as well as targeting inspection resources in areas where there is greater risk.
This would include more analyses of short and long-term trends in providers’ performances, developing data that predicts risks, improving its use of inspection intelligence and risk assessment, and improving the way it uses service users’ feedback.
It would also have to improve how it interprets and disseminates its risk intelligence products and identify key intelligence triggers for regulatory action.
More responsive and tailored inspections
The last option is similar to the risk-based approach in the sense that it would tailor inspections to target providers at greater risk. For example, it would inspect ‘good’ or ‘outstanding’ services less frequently or less intensively than other services, instead relying more on other sources of assurance besides inspection.
But this approach would only be possible if the three other areas are taken forward.
If implemented, it would reduce the number of large comprehensive inspections of all services offered by a provider at the same time. It would also further align inspection activity with other partners in the sector to make sure efforts are not duplicated.
The commission will also ensure that inspections always take into account and support the development of new models of care.
(Top image c. PA Archives)