CQC strategy 2016-21: consultation response
The CQC has made significant progress in implementing an ambitious new model of quality regulation and inspection over the last three years. Despite some delay to its initial commitments, it has now inspected over 60 per cent of NHS foundation trusts and trusts and is in a position to review and adapt its operating model to ensure it is responsive to changing context in the NHS, adds value and is sustainable in the long term.
Our response is based on our regular dialogue with colleagues at the CQC and our member foundation trusts and trusts, as well as intelligence from a dedicated member engagement event held in partnership with the CQC on 18 November 2015 to discuss the issues considered within the strategy in detail.
- We welcome the recognition within the consultation document that the health and care landscape is changing and that the CQC is proactively seeking to flex its approach accordingly; the landscape will change radically over the life of this strategy, and an increasingly complex and diverse system will require a regulatory model that is sophisticated, consistent and manageable. Starting from a relatively ‘young’ regime, the CQC will face a challenge to allow sufficient flexibility in its plans, particularly to respond to the development of new care models and to ensure an appropriate balance of activities in a system in which accountabilities are institutionally focused but which strives to work at the level of area based partnerships.
- We remain supportive of the fundamental role of quality regulation assigned to the CQC, which is one of setting minimum, national quality standards and identifying where services fall below those standards through a risk based and proportionate approach. We welcome the CQC’s continued recognition that the primary responsibility for the quality of care delivered to patients and services users appropriately lies with provider boards and their staff. We also welcome the focus in the strategy on better use of data, and more targeted and risk based inspection.
- We would welcome further discussion about how the CQC sees the balance of its investment in the different themes set out in its strategy consultation. For example our preference would be to see the CQC focus primarily on its core responsibilities as a risk based quality regulator, but allow some time to invest in work to explore ‘quality in a place’. We would welcome greater clarity on how the special measures and success regimes fit into the CQC’s five year strategy.
- It is of paramount importance that the model of regulation and inspection is affordable for the sector as a whole, for the regulator, and for the institutions being regulated. In this context, we note that the rising level of registration fees has been an increasingly contentious issue across the regulated sectors. We welcome the CQC’s renewed focus on ensuring it maximises the value it adds for providers and the public, and lives within its means.
- Some of our members continue to express concern about the suitability of CQC’s methodology for monitoring and inspecting providers of non-acute services. We strongly encourage the CQC to sustain its focus on ensuring its inspectors have a greater understanding of different types of service, including community, mental health, ambulance and integrated services; to develop its model for these sectors around the services themselves, rather than adapting an acute model retrospectively; and to ensure its language reflects this.
- A close collaboration with NHS Improvement and other national partners will be essential to the success of this strategy over the next five years. The formation of NHS Improvement offers a unique opportunity for the organisations to work together to review the regulatory framework as a whole and ensure it is streamlined, fit for purpose and adds value. The time is right for them to clarify their roles and responsibilities in line with their capacity and capability, and where they can work together to minimise duplication.
- In the long term, we would welcome consideration of the possibility of a single regulatory body with quality as its driving principle. Overall, we would be pleased to see the sector move towards a system of robust internal assurance and peer review to support continuous improvement, with the appropriate nationally led, regulatory checks and balances in place.