CQC's second next phase of regulation consultation
Our response covered the proposals in the consultation that are cross-sector in nature and will therefore affect our member foundation trusts and trusts. This includes how the CQC is proposing to amend its approach to regulating complex providers, its plans to develop a provider-level assessment across all sectors and the additional guidance on interpreting certain of the requirements under the fit and proper persons regulations.
Our response covered the following key points:
Monitoring and inspecting complex providers
- We welcome the proposals regarding how the CQC plans to coordinate its approach to regulating complex providers, but call for greater clarification around the implementation of these plans and the associated timescales, especially in relation to the integrated approach to regulating accountable care systems (ACSs) and organisations (ACOs).
- We urge the CQC to work with NHS Improvement and NHS England to ensure their approach to assessing system-wide leadership is aligned with STP ratings.
- The CQC's four possible options for provider-level assessment of all sectors lack sufficient detail to enable the CQC to make an informed choice about which option to pursue.
- In addition, whichever approach the CQC takes will necessitate further consultation before implementation.
- We comment on the four options and make several suggestions, such as assessing and rating up to five key questions at provider level which can then be aggregated into a single rating.
Encouraging improvements in quality of care in a place
- We would welcome a greater focus on assessing how well providers are working together as part of its provider inspection reports.
- We agree that reviews of local health systems are useful, but call on the CQC to ensure that they do not detract from other priorities such as the roll-out and implementation of its revised regulatory model.
Fit and proper test
- We welcome the proposal for the CQC to share all the information it receives about fit and proper persons concerns with providers, but believe the CQC should test the utility and clarity of the detail in its guidance. For example, the guidance should clarify that the CQC's role is not to determine whether a specific person meets the requirements of the test, but to assure itself that providers have robust processes in place for complying with the regulations.