New CQC focus from 6 October – transitional regulatory approach

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Please Note: All information is correct at time of writing on 6 October 2020. We do our very best to make sure our information is as up to date as possible, but we’d encourage you to check out the CQC’s website for the latest updates and guidance.

In response to the pandemic and pressures facing the care sector, the CQC paused routine inspections and developed an emergency support framework which was an adaptation of their usual regulatory approach.

From 6 October, the transitional regulatory approach will begin to roll out starting with adult social care and dental services, which will bring together existing methodologies with learnings from its COVID-19 response.

Significantly, the CQC has said its new inspection activity will be more targeted, focused, and that it would not be returning to a routine programme of planned inspection. Undoubtedly, they will continue to review the impact being felt by the care sector as infection rates continue to fluctuate between regions and they will respond accordingly.

Our in-house care experts have summarised the key points providers should note.

What are the key components of the transitional regulatory approach?

The CQC states that the transitional regulatory approach is flexible and will build on some of the key learnings from the pandemic.

There are three key components of the approach:

  • More targeted and focused inspection activity, focusing on where the CQC have concerns.
  • Better direct contact with key stakeholders (service users, staff, and families) using technology and their local relationships.
  • Strengthened approach to monitoring, with clear focus areas based on existing Key Lines of Enquiry (KLOEs).
  • Having reviewed the information they have on your care service, the CQC will have a conversation with you by telephone or online (which they state is not an inspection and following which they will not rate your services). This call will help determine if further action (such as an inspection) is required at this time.

What will the CQC be monitoring?

Having focused their efforts in the last few months on managing the immediate risks from the pandemic, the CQC will be broadening their monitoring approach to look at more areas where quality needs to improve.

Based on their existing KLOEs, the CQC will specifically target safety, people’s access to services, and leadership (though the CQC can still look at any, or all the KLOEs).

Information will be monitored and reviewed from all available sources, with further information collected where necessary. This includes previous inspection reports, ratings, and the inspector’s knowledge of your service.

Central to this will be feedback and experiences of those involved in the care service including families, staff, and service users. The CQC can gather this from responses to the online feedback survey along with other enquiries and information.

Note: As a Citation client, you can benefit from our CQC Pro product and its survey tool. CQC Pro users can easily send out surveys as often as needed and immediately receive reports, so you can compare different responses and gain valuable insights and trend analysis.

The professional judgement of inspectors will also continue to underpin how the CQC monitors risk, with inspection teams able to act quickly and make their own judgements, where information sources may suggest greater levels of risk elsewhere.

How will the CQC gather and collect information?

Once they have gathered the necessary information, the CQC will arrange a call with you.

Where possible, this will take place using Microsoft Teams, though it can also be done by telephone. Where Teams is used, you will be sent an invitation with a joining link for the agreed date and time.

The call will cover the specific KLOES for your type of care service (these can be found on the CQC’s website here for adult social care and here for primary care dental services).

The inspector will make notes of good practice and improvements across your service, any specific risks identified, and discussions around the questions raised within the KLOEs. The calls will not be audio-recorded except in specific cases and your consent will be obtained at the start.

Following the call, the inspection will prepare an overall monitoring summary of their findings.

In some cases, the CQC may request specific evidence, in which case you may be able to share your screen or send over an attachment by email. If using email, this should be encrypted or password-protected (the CQC can explain how to do this) and must be done within 24 hours.

Citation clients who are CQC Pro users can use the platform to help with their preparedness and organisation, collating evidence which they can then easily show by sharing their screen.

What happens after the call?

If the call indicates there is no need for an inspection or further action, you will be sent a copy of the monitoring summary record. This is not an inspection report and so does not include a rating.

Further regulatory action can be taken if the monitoring activity indicates there is risk to the safety of the people using your service.

This could include finding additional sources of support, an on-site inspection, and enforcement processes. In this case, you will not be sent a monitoring summary record.

Will on-site inspections continue to take place in the future?

The CQC has been very clear in that it won’t be returning to ‘business as usual’. There will be no return to its fixed timetable or frequency rules on inspecting, with a return to its published frequency unlikely anytime soon.

On-site inspections will still be carried out but in a much more targeted way. Whether or not you will be visited will depend on the information the CQC has collected. Visits are more likely to happen where the CQC believes people are not receiving adequate care, or if services need more visits (e.g. in secure settings).

Will my care service be rated and will I receive a report on the CQC’s findings?

To demonstrate the quality of your care service, and to help maintain and attract new business, we know that ratings and information matter.

The CQC has said it will make a judgement about your care service after its information gathering and monitoring. If your care service is indicated to be of a low level of risk, the CQC will inform you of this and no further action will be taken.

In future, the CQC says it will publish a short statement on the websites of care providers, as well as sharing a summary directly with them, but initially wants to see what works for service users and providers.

Due to inspections focusing more around areas of risk, all five key questions, and KLOEs may not be covered, inspections may not lead to a change in rating.

In addition, the CQC has said its ability to re-rate services is limited and will only be able to do so in a limited number of cases.

How Citation can help your care business

To supplement our HR, Employment Law and Health & Safety support, we’ve developed a suite of products bespoke for the sector to help take the stress out of compliance.

These include Care Mock Inspections, Care Policies & Procedures, care-specific elearning, and CQC Pro – a digital tool that gives you the power to build a robust body of evidence to demonstrate your commitment to quality and prepare for any CQC inspections.

If you’re not yet a client and are interested in getting the backing of our expert team, simply fill out your details on the form opposite and we’ll be in touch as soon as we can. You can also give our team a call on 0345 844 1111 to talk through your business needs.

If you’re an existing Citation client and would like to find out more about our care additional services, please call 0345 241 5250. Alternatively, to get through to our 24/7 advice line please call 0345 844 4848. 

To help you check you’ve got everything covered, below are some of our care-specific guides and resources which may find helpful.

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