So, what next?

It seems likely that the inspection regime will move to a more risk-focused system using ‘focused re-inspections’ and ‘unannounced inspections’ as the main tools to ensure ongoing regulatory compliance. These are likely to focus on particular core services or known high-risk issues such as A&E performance or nurse staffing.

The CQC’s new 5 year strategy states that the CQC still sees inspections as central to an assessment of quality. However, in the future there will be a focus on providers who have demonstrated poor care or, where a change in quality is more likely. It seems logical therefore that the focus will be on Trusts who have current ratings of Inadequate and Requires Improvement. These unannounced inspections are already taking place and are being targeted on the basis of intel gathered at previous inspections, risk summits and specific concerns voiced to the CQC by staff and patients. We have seen very recent examples of Trusts being given a start date for a focused re-inspection, only to find the CQC turning up unannounced 7 to 10 days beforehand the planned date. We anticipate that this approach will continue as the CQC continues to grapple with the familiar challenge of having a large mandate but only limited, and ever reducing, resources to deliver this.

A clear reputational issue already emerging from these re-inspections is the CQC’s lack of process on how it amalgamates any new ratings awarded with the old ratings (those applied at previous inspections for services not subject to re-inspection) to find the new overall rating for an organisation. There is clear CQC regional variation on how the new and old ratings interact. It becomes difficult for providers, therefore, to understand what specific rating they have a duty to publicise. Unsurprisingly, the result is public confusion around the overall rating for an organisation.

How we can help you

If you feel that you may be the subject of re-inspection and require assistance to prepare for the inspection, we have a range of interventions designed to bring external scrutiny to your preparatory work, including focused mock inspections, mock listening and staff engagement exercises and mock interviews for Board members and senior leaders.

We have also helped a large number of NHS Trusts to successfully challenge the accuracy of CQC draft reports and have secured improved ratings as a result in over 80% of cases dealt with. We help providers raise appreciative enquiries and make constructive comments to the CQC to ensure that the final published reports are clear and accurate.

We have gained unrivalled national experience by dealing with CQC inspection and regulation issues across the country and use this to give you genuine insight into the approach of the CQC; helping you to secure the right result for your staff and patients.

For more information please contact Ian Cooper on 0113 323 1060 or Siwan Griffiths on 020 8780 4887.