NHS providers submission to CQC's consultation on flexible and responsive regulation
- We welcome CQC’s intention to move away from relying on set-piece on-site inspections and draw on a wider range of regulatory approaches that can be completed remotely in a more timely manner
- However, it is important for CQC to ensure its approach is applied consistently and equitably across all providers and sectors. The criteria for undertaking an on-site inspection or using other regulatory approaches should be clearly set out. CQC should consult on this criteria before implementing the new model
- We are supportive of using inspections where necessary and proportionate, as they are useful in providing a clearer picture of the culture, including closed cultures, and behaviours within an organisation that may influence quality.
- It remains important for CQC to meet its ambition to reduce unnecessary burden. We would encourage CQC to also consider streamlining the submission process for trusts and work more closely with other bodies including NHS England and NHS Improvement to streamline regulatory requirements.
- While there are benefits to updating trust ratings more regularly, there are also risks arising from changing them too often. CQC should set out a clear framework outlining how often ratings could change, ensuring the threshold is not too low and setting a minimum and maximum time period between changes to a trust’s rating. CQC should consult on this framework.
- We understand CQC’s aim of simplifying the way it determines trusts’ ratings, which currently relies on multiple levels of complex and aggregated ratings. It is important that ratings, and the underpinning methodology are clear and relevant to all users including patients, the public, and providers themselves.
- We do have concerns that basing trust-level ratings solely on the well-led key questions (at trust level and service level) will not represent a true picture of the quality and safety of services being provided within the trust. CQC must consider how to ensure that the quality of care provided by staff and providers is fairly reflected and ensure that service users are able to access information on the quality of services they receive.
- Before placing a stronger emphasis on the well-led key question for trust level ratings CQC must ensure that the well-led framework is fit for this purpose and robust enough to use as the underpinning for trust-level ratings.