Introduction
On 16 October 2025, the Care Quality Commission (CQC) published its consultation on proposed changes to the way it assesses and rates health and social care providers. It is called ‘Better regulation, better care’ and the public have until 5pm on 11 December to respond.
Context
It is almost five years since CQC issued its last consultation on proposals for a more flexible and dynamic regulatory framework. The consultation back in January 2021 was ambitious and groundbreaking as it proposed a move to a system of real time regulation based on ongoing data collection and analysis. CQC said at the time that it would not always be necessary to carry out inspection visits if it wanted to update ratings. Unfortunately the implementation of this strategy after December 2023 – known as the Single Assessment Framework (SAF) – was spectacularly unsuccessful. CQC acknowledges the failures in the new consultation. It is time to move on.
Key proposals
In many respects, CQC is proposing to go back to what it was doing before the introduction of the SAF. Key proposals are:
- Reintroducing assessment frameworks that are specific to each sector with supporting guidance. The supporting guidance will show “the key standards and sources of evidence that we will consider for the services in that sector.”
- The assessment frameworks will be simpler and clearer. CQC proposes to abandon scoring altogether under the five key questions: safe, effective, caring, responsive and well-led.
- Replacing the quality statements with what are called “supporting questions” which will be similar to the previous Key Lines of Enquiry.
- Re-introducing rating characteristics for each rating: outstanding, good, requires improvement and inadequate.
CQC says the inspectors will carry out a “rounded assessment of evidence with reference to ratings characteristics.”
Types of inspections
Two types of inspections are referenced in the consultation:
- Routine planned inspections, “where we plan to take a broad and detailed look at the quality and safety of the services.” These would generally be carried out on a 3 to 5 year cycle.
- Rapid response inspections, “where immediate and specific concerns are identified. Inspectors will be deployed to understand the nature and significance of problems and will focus on areas of particular risk.”
CQC says, “We would not expect to look comprehensively at every area of every service or cover every part of the assessment framework every time we inspect a service. However, we would expect that routine planned inspections would normally cover all of our 5 key questions, so that we fully understand the quality of the service across the framework before updating our overall ratings.”
CQC adds:
“When updating our ratings, we intend to minimise the mixing of new evidence with evidence gathered in previous inspections, especially where those inspections were carried out several years previously.”
This statement shows a lack of appreciation of the need to rate services based on the position at the point of inspection. It should not be based on previous evidence from an earlier inspection at all.
Frequency of inspection
One of the major weaknesses of the current regulatory framework is the absence of a defined frequency of inspection. As a result, services can go many years without having a CQC inspection. CQC says, “we intend to introduce a frequency schedule for individual health and care sectors that takes into account previous ratings and other factors such as emerging risks.” This is to be welcomed. Indeed, it is a legal requirement which CQC has ignored for years.
Inspection reports
Current inspection reports are often vague and confusing. CQC says, “For providers, we want our inspection reports to provide detail of our judgements and support them to identify areas for positive change and continuous improvement. We recognise that providers need detail in our reports to understand why they have received a particular rating and to relate to other providers.” Again, this is welcomed.
Relations with providers
Most CQC inspectors carry out their duties in a professional and dignified manner. However, at Gordons Partnership we do come across cases where individual inspectors fail to uphold the high standards expected of them. Therefore, the commitment on the part of CQC to ensure there are professional relationships with providers based on respect and trust is welcomed. As CQC says, “however good our regulatory model, standards and processes are, our impact depends crucially on the people who implement and experience our regulation. We aim to ensure that we consider the impact of our work on the providers that we regulate, including the wellbeing of their staff.”
Conclusion
CQC’s consultation is high level and modest in its aims. That is a good thing. Reverting back to the model that was in place before December 2023 is sensible and obvious. No doubt improvements can be introduced to it along the way.
CQC says it is committed to testing everything properly first. Sadly that didn’t happen with the SAF. We have had too much drama in the past two years. Please, CQC, get it right this time around for all our sakes, most importantly for the people who use services and seek assurance about their quality and safety.
About the Author
Partner
Tel: 01483 451 900
Email: Neil@gordonsols.co.uk