CQC consultation on regulatory fees from April 2018: NHS Providers response
NHS Providers welcomes the opportunity to respond to CQC’s consultation on regulatory fees from April 2018 on behalf of our members. Our response focuses on proposal 5 in relation to NHS providers as this is the proposal in the consultation affecting our membership.
Key messages include:
- Any Care Quality Commission (CQC) fees scheme structure needs to balance fairness, proportionality and simplicity. We support CQC’s ongoing commitment to look carefully at the costs incurred by regulation.
- We support CQC's ambition to charge fees as fairly as possible and recognise that CQC has faced a significant challenge in moving to a full chargeable cost recovery model by 2017/18, as required by HM Treasury.
- From the options proposed by CQC, we would support the option with no minimum fee (floor) and no maximum fee (ceiling) as this model is most closely aligned to a scheme which is equitable and fair. However, this option is problematic as some providers will see their fee rise substantially.
- While we welcome the reduction of fees paid by around 75% of providers under the proposed changes, we are concerned that around 25% of providers will see a substantial increase. The largest fee increase is expected to be from a fee of £332,248 to a fee of over £1 million. Any fee increase represents an unfunded cost pressure and is difficult for providers to accept at a time of significant financial, operational and demand challenges.
- We urge CQC to avoid imposing any immediate increase for 2018/19 and instead to adopt a transitional period and more gradual pace towards implementing any change for the providers that will see a substantial rise. We also urge CQC to recognise the importance of a ceiling in the future. If NHS providers continue to grow in size, CQC will need to consider a ceiling to restrict the highest possible fee paid by an individual provider and thereby prevent fees from rising to unsustainably large sums that do not necessarily equate to the cost of regulating them.
- Given CQC’s efficiencies and strategic approach, providers expect to see a commitment not to raise fees, in the future, as well as stability in the amount paid year on year and a reduction in fees over time.