Response to CQC and NHSI consultation on reporting and rating NHS trusts' use of resources

NHS Providers welcomes and supports the joint approach the CQC and NHS Improvement are taking to reporting and rating NHS trusts’ use of resources, and their commitment to test and refine the process over time.

• It is helpful that quality and finance will not be looked at in isolation but as part of a whole assessment of a trust’s performance. This is particularly the case given that a trust may be using its resources efficiently but overall quality may be affected by a general lack of resources. However, for a number of reasons, including comparability, it is also important to judge quality on a ‘finance blind’ basis; we have some concerns that use of resources ratings risk obscuring good quality care being provided by trusts.
• The inclusion of a use of resources rating by the CQC will add further complexity to how a trust’s performance is judged, which is already more complex than any other sector that the CQC regulates. This has implications for trusts, for the consistency of ratings between trusts, between different sectors and also for patients’ and the public’s understanding of the CQC’s rating.
• We are concerned that the introduction of Use of Resources (UoR) assessments and ratings for non-specialist acute trusts only creates inconsistencies between providers in how they are assessed. This has the potential to be further compounded by the addition of a sixth key question to the current aggregation rules. There needs to be a level playing field for provider organisations. We urge CQC and NHSI to start developing sector-specific approaches for the specialist, community, mental health and ambulance sectors as soon as possible, with meaningful engagement with the sector.
• Overall, we welcome the balanced approach of adding the UoR rating as a sixth key question, but maintaining a separate quality rating overall, does not over-emphasise UoR at the expense of the other key questions.
• However, we would like to ensure that it is the overall quality rating that is displayed within trusts, rather than the overall combined rating. It is the quality rating that is of most interest to the public. Given that not all trusts are currently assessed for UoR this will be the only way that the public is able to understand and compare the quality of care provided in trusts. We urge CQC and NHSI to engage patients and the public in developing ratings displays and explanations for the ratings.
• While we welcome NHSI’s assurance that it will draw on relevant local health economy intelligence to inform the assessments, we remain concerned that the regulatory approach to assessing use of resources, which focuses on individual organisations in isolation from the rest of the system, does not fully take in to account the local and national factors that influence trusts’ performance.