Ian Trenholm’s blog post, which was published on Tuesday 26 March 2024, could be easily missed in the excitement of the run up to the Easter weekend but it contains some essential updates for providers.

Additionally, the CQC Board Meeting on 27 March 2024 also provided a helpful update about the Single Assessment Framework and how CQC are attempting to address concerns that have been raised both internally and externally in order to implement the framework across the services that they regulate.

Quality Statements

Most notably CQC have taken steps to address the very serious concerns from the sector about the very limited number of quality statements that have been considered in the first of the published reports under the new framework.

At the time of the CQC Board Meeting, Ian Trenholm confirmed that 13,025 assessments had been commenced under the new framework. There are 34 Quality Statements.  The average number of quality statements reviewed per assessment is currently ten. Specifically for adult social care services, the average number of quality statements increases slightly to eleven. This leaves over two thirds of the quality statements untouched.

The concern is that currently unless the quality statement has been specifically considered, historic findings have been transposed into the new scoring system which could have a significant negative impact upon the new ratings. Therefore, despite CQC’s ambitions, any assessment that draws on these historic findings would not present an up-to-date picture of the service at all.

The blog states “When carrying out an assessment of a service that is either inadequate or requires improvement all quality statements under the key question that are rated inadequate or requires improvement will be reviewed”. The Board Meeting also confirmed this position.

By confirming that Inspectors will be considering all quality statements under any key questions previously rated as Requires Improvement or Inadequate, the concerns about historic ratings impacting upon the new ratings are alleviated for now. It will be important to review how this will work in practice and the implications for providers.

Frequency of Inspections

With regards to frequencies of inspections, the blog says that CQC “aim to publish timelines in the summer.”  This is consistent with the update on 27 February 2024 which highlights that they will be reviewing how well the Single Assessment Framework is working up until the end of June 2024. They intend to publish their findings at the start of July 2024.

It is disappointing that CQC have still not yet complied with their obligation to set out the frequency with which ratings assessments are to be conducted and the period to which they are to relate under section 46 of the Health and Social Care Act 2008 as Neil Grant and Tim Dallinger set out in their article here.

Provider Portal

The roll-out of the new provider portal has been rather disastrous for CQC as they have encountered numerous technical difficulties. The blog post confirms that they are continuing to improve functionality and make further improvements in the ‘coming weeks’.

As of Sunday 31 March 2024, the old provider portal is now permanently closed.

In the CQC Board Meeting on 27 March 2024, the issues with the portal were acknowledged. They have set out some guidance on their website to assist providers.

It is helpful to note that if you are having trouble submitting notifications, they recommend making notifications via email. It will be important for providers to keep a suitable record of attempts to notify CQC, especially if they are having technical difficulties in submitting these notifications. Maintaining clear records will be vital in order to demonstrate that providers are compliant with the regulations.

Additionally, in the CQC Board Meeting it was acknowledged that the delegated access function is in the process of being revised. When this was first rolled out there were significant issues therefore it was withdrawn and is now in the process of being updated and tested.

Conclusion

It is apparent that the road to the implementation of the Single Assessment Framework is a going to be a bumpy one.  The framework is well intentioned but practical concerns and uncertainties about implantation remain. It is evident that there is significant discontent internally within CQC beyond what might be expected simply from adapting to change.

As more and more assessment reports are published under the new framework, practical implications for providers will become evident. It will be vital for providers to keep abreast of the changes and updates and to voice their concerns where necessary.

About the Author

Lucy Bowker
Solicitor