The Dash Report - What it means for you as a provider and next steps
The Dash report into the Care Quality Commission (CQC), supported by Sir Mike Richards’ review of the Single Assessment Framework (SAF), will have significant implications for regulator, and for providers currently getting to grips with the new assessment framework.
While providers can’t influence the CQC’s internal operational challenges, they can work proactively to ensure that they are prepared for the potential impact of them. We have identified the following key issues for providers and potential next steps:
Outdated ratings may mask more serious quality concerns
Dash starkly highlights the impact of reduced operational capacity within the CQC, and the proportion of providers with ratings up to ten years old, as well as the number of more recently registered providers that have never been inspected. This increases the pressure on organisations and organisations should be asking themselves the following questions:
- ‘Good’ and ‘Outstanding’ organisations – are you still challenging yourselves to improve, or could you have been resting on your laurels?
- Are you regularly checking services, both internally and by drawing on external assurance where appropriate?
- How confident are you in your ongoing quality management system? Is it providing appropriate assurance and supporting continuous improvement?
- How are you countering or challenging optimism bias when you ask your teams and services to review their performance against the CQC’s framework?
Inspectors’ potential lack of understanding of specific services makes communication and information sharing even more important
The lack of relevant experience within inspection teams was highlighted. While this needs to be addressed over the medium/long term, the CQC’s priority will be to increase capacity with the team it has. Therefore, it’s mutually beneficial for providers need to make it easy for inspectors. This includes sharing information with them transparently, while also sharing contextual information about services and pathways. This will help inspectors get the best view of services, which they can test through assessment.
The CQC’s will prioritise assessments based on risk
Pragmatically, to address their assessment backlog the CQC will take a risk-based approach. Organisations therefore need to take seriously the escalation of risks within services, as well as patient feedback and whistleblowing. If the CQC thinks that risks and whistleblowing are not being positively addressed, you’re more likely to be inspected. Make sure that your systems and processes are robust, and you are responding to feedback and concerns quickly and effectively.
The new CQC single assessment framework (SAF) needs to be developed further, but you have to understand it, and work to it for now
While Sir Mike Richards identified a string of improvements to be made to the SAF, the SAF itself is here to stay and teams throughout organisations need to increase their understanding of how it operates and applies to their services.
Richards’ report identified the need for the CQC to develop better guidance so that organisations and individuals know what good looks like. While we wait for this, your quality teams need to fill that void – communicating expectations and supporting teams to deliver safe and effective services.
Even with all this change, the regulations remain the same – make sure you can evidence that you’re meeting them
The SAF may evolve, but the regulations haven’t changed and are the fundamental measure of quality and safety. Increasing numbers of organisations are found to be in breach of regulations, receiving action plan requests (formerly called Requirement Notices) from the CQC. Failure to meet regulations with the CQC’s current operational pressures means that providers may be stuck with ‘Requires Improvement’ or ‘Inadequate’ ratings for a significant period of time.
We welcome the Dash and Richards reports and will have a lot more to say on this over the coming weeks – and months as follow-up work is completed.
Please reach out to us if you have any questions or concerns about anything you’ve seen in these reports or think your organisation would benefit from support in this area.