The CQC is under investigation, in terms of how it operates and how it inspects healthcare providers. Dr Penny Dash began a review in May 2024, and here FPM distils its interim findings. 

The new Single Assessment Framework - rolled out from November 2023 - is a risk-based approach, in which practices are compared against one another. The CQC has said that the aim of the new SAF is to be fairer. We know that where human factors are involved, there may be some slight discrepancies. If you feel that you have been treated unfairly, you should ask to speak to the CQC area manager. You can do this by calling the main Newcastle CQC phone number.

Dr Penelope Dash was asked to carry out a review of CQC in May 2024. Over the last 2 months she has spoken to around 200 senior managers, caregivers, and clinicians working across the health and care sector, along with over 50 senior managers and national professional advisors at CQC.   

Here FPM distils part of the Dr Penny Dash interim report to find out what may have gone wrong.

There is no description of what ‘good’ or ‘outstanding’ care looks like, resulting in a lack of consistency in how care is assessed and a lost opportunity for improvement:

• Descriptions used in the old framework for each quality statement (QSs) have not yet been developed for the new one
• This prevents organisations from being able to improve – they just aren’t sure what inspectors are looking for, and inspectors can’t articulate it properly themselves
• There’s a worrying lack of consistency where organisations are spread across different sectors – large groups of GP practices for instance, who get very different ratings across sites due to misreported differences

There is a lack of focus on outcomes (including inequalities in outcomes):

• Surprisingly little focus on outcomes of care (just 2 out of 99 QSs refer to this) – despite the fact that there is a lot of data about it within primary acre (for instance, how having well-controlled diabetes impacts on care)
• The CQC do not use the more than 30 clinical audits called GIRFT (Getting It Right First Time), whose data could be used to make more accurate comparisons of provider outcomes
• Barely any measures looking at independent sector provider outcomes or outcomes by different population group

The way in which the SAF is described is poorly laid out on the CQC website and not well communicated internally or externally:

• The review found the info confusing, so providers are likely to also. Basic things like structure and numbering of info was lacking.
• In the CQC executive team, few members could describe the 34 QSs or the 6 evidence categories and their rationale for using them.

The data used to understand the user voice and experience, how representative that data is, and how it is analysed for the purposes of informing inspections, is not sufficiently transparent:

• It is not clear enough what data is actually looked at – and there is no published account of the statistical analysis the CQC uses on this data, in terms of required response rates for example. Most data is taken from national surveys and then added to using interviews from service users. But these interviews often use a tiny number of people from services affecting thousands. Only 6 cases per local authority assessment are tracked, and this is regardless of the size of the authority, prompting concerns over how representative the data is.
• The CQC is not yet assessing providers on whether they are specifically seeking the views of those who have poor experiences of care or who fast the most barriers
• There is no reference to use of resources or efficient delivery of care in the assessment framework which is a significant gap despite this being stated in section 3 of the Health and Social Care Act 2008: Within the new SAF framework there is no quality statement that refers to the “use of resources” and how efficient care delivery is (the CQC can request it from NHSE but in practice rarely does this). This is particularly disappointing, as assessing how effectively resources are used is one of the best ways of improving care quality.
• Staffing is a crucial part of the success of healthcare, but yet the QS on effective use of staffing doesn’t itself consider whether services could be delivered in a more efficient way.

The review has found limited reference to innovation in care models or ways of encouraging adoption of these:  

• The review didn’t find any evidence of the CQC considering systematically how providers are innovating in their care delivery. They don’t look for example at how providers are adopting technology or using elective care centres or new models of care. The review describes this as a missed opportunity to drive better care.

The CQC has appointed Professor Sir Mike Richards to conduct a targeted review of how the single assessment framework is currently working for NHS trusts and where they can make improvements.

In this period of change it’s more important than ever to get the basics right and know how to be CQC-ready. Thornfields offers a workshop called Preparing for a CQC Inspection which will help you. FPM Core users get access to an Inspection Checklist as part of the CQC Inspection Guidance Toolkit. And on our YouTube site you can see a video of our latest expert-led webinar on How the SAF Is Going So Far. We will update our materials as and when new information about the CQC and their inspection framework comes to light.