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Update from CQC Trade Association Meeting – 25 August 2021

The August CQC trade association meeting covered some useful topics. See slides: August Trade Association Meeting Slides and the meeting minutes: August Trade Association Meeting Minutes

Latest update on CQC publications

The CQC has now launched their strategy. The strategy outlines how they plan to change and transform to deliver more effective regulation. To ensure that the delivery of this strategy is effective they want to develop how they will implement it in partnership with you.

The CQC has created an implementing our new strategy project folder. In this folder, you’ll find lots of projects to get involved with to help implement their new strategy. Now is the time to shape and influence their early thinking.

You can provide feedback on:

Find out more and share your views by logging in and visiting the project folder.

Provider Information Return – Relaunch

The CQC have listened to the concerns around the burden of completing the PIR.

  • They have reduced the number of questions that are asked, and the time taken to complete has been reduced from 18 hours to 11.
  • The first month of the update was used to test the new questions and the timing of the relaunch. So far, they have received positive feedback and a response rate of 84%.
  • They will continue to limit the requests being sent to locations currently reporting outbreaks using information from the capacity tracker.
Data sharing of the PIR
  • The CQC are using the PIR as part of their monthly monitoring approach
  • They are also using it more widely & sharing it more widely across other parts of the sector
  • When asked for further clarity on what level of data is shared, CQC advised that it is detailed in the PIR guidance & the data listed is shared with DHSC & SfC; – a small no of questions for internal purpose and is shared at the individual location level
Next steps on sharing

The LGA have asked for it to be shared at location level & more widely with LAs, but the CQC want to talk to us as provider reps first to explore opportunities and challenges. The PIR offers a lot of useful info and CQC want to maximise its value.  

The CQC are looking to run a session with RMs, the trade associations & people with lived experience to contribute to a workshop & look at especially sensitive questions

Action: advertise the workshop & encourage NCF members to attend


CQC Quality Assurance Process

The CQC offered an update on their QA processes, following a meeting with Care England in July, where they ask ‘what do CQC actually do in terms of QA as part of their inspections?’

See slide 9 for the details. Points to note: new inspectors do go through a robust induction process, note the process for review of all Inadequate & RI ratings, the sampling approach for the review of Good rating & the review of all Outstanding ratings. Inspection Managers are on a rota to review reports, which offers objectivity & consistency.

Factual accuracy comments; if the IM was involved in the inspection in any way, they cannot deal with these QA issues; if the report is complex, it may get a second review.

Ratings review – this allows for a review to check if the process has been followed properly. Only happens after an inspection has happened. See here:

There is a complaints process is available too if providers are not happy with the whole process.

IMs also observe a sample of inspection practice usually – not in COVID, but will start again soon.

Question: If a service has a lot of positive feedback to suggest Outstanding, can the process be simpler for those services in the QA process? Answer: CQC say that services that are clearly Outstanding move through the QA process at pace already.

The CQC then also have a retrospective process, looking back to see what they learn from the QA processes. They try to take a cross-sector approach. They have a National Quality & Improvement Group (NQAI) which drives the topics for consideration, the overall review & the actions from it.

This year, the CQC has also done 3 Appreciative Reviews (see slide 11); these look at good practice & aim to encourage people to reflect on & learn from their practice.

We asked if this process takes provider feedback into account? It doesn’t at the moment – they will consider this.  

We also suggested the voice of the customer should feature in these reviews – as well as the voice of the people using the service who took part in the inspection.

COVID 19 Sector check-in

What’s the vibe? We all raised the issues of workforce pressures

We also asked what we should be advising providers to be telling the CQC? 

See their response from the chat below:

Para 15 covers the bit around reg 18 (notification about ‘other incidents’)

Events that stop, or may stop, the registered person from running the service safely and properly. You must notify us about any relevant infrastructure, equipment, premises or other problems that prevent, or are likely to prevent, you from carrying on the regulated activity safely and in accordance with the fundamental standards.

Operational Update
Vaccination as a Condition of Deployment

Quite a high level of concern from CQC about this, especially after the DHSC webinar, which suggested that providers were struggling with the guidance and the scope of the policy.  

CQC pushing for 2 things:

  1. This policy is not just for care homes to implement; everyone providing health & care to care homes has a responsibility to make sure their staff meet the VCOD regulations;
  2. Easy read summaries of the DHSC’s guidance to support the sector

CQC are trying to make it all as simple as possible. RMs & providers know their services best; CQC won’t be prescriptive; they want to support & enable RMs to meet the regulations as best they can.

Advice for providers is to take a risk assessment approach, talk to teams, decide how to put it into practice, note your approach & keep it under review.

The regulation is very binary, so they have little discretion in deciding what is or is not a breach; where their discretion comes in in the action the CQC takes as a result; they will look at their options from warnings onwards.

  • Question: What about the issue of deploying unvaccinated staff? Answer: If this is the only way to ensure safe treatment & care, then providers need a clear documented risk assessment and help the CQC to make a judgement about the wisdom & necessity of doing this and the full circumstances surrounding it.
  • Concerns regarding the data integrity on Capacity Tracker; LA intelligence suggests between 5% – 20% of the workforce are not vaccinated, there may be gaps in the data so far
  • Question: about the MRHA only approved vaccines only issues – some employers seeking Tier 2 status to bring staff in from abroad & they will have other vaccines.
  • Question: about any H&S requirements for exempt people in the situation where visitors are not required to be vaccinated?
  • Question: about insurance issues also?

CQC have flagged these issues to the DHSC and will be looking closely at the monitoring impact of this post 11 Nov including the number of breaches & action taken.

Update on Transforming the way we regulate services for people with LD & autism
Home for Good report

Due around 8 September – 8 stories of people who have had many placements, via the hospital system, now living in services designed for them around their needs, in communities – really positive.

Quality of Life Tool

Been piloted for service inspection; looking at it, but want providers to see what they are using – may tweak it going forward. Takes people from the plans into a view of what people really need to live their lives well & gets under the way staff work with people; it uses a comms tool to help to understand what is it like for the people living in the service. Very pleased that this is being published!

Pilot with Experts by Experience

This is an important pilot: they want to explore how to have an ongoing presence & involvement from Experts by Experience with the service and the people using it to see what is happening, changes in care & what it means for the people using the service.  Introduced in Sept; an E by E is linked to service & keep contact post-inspection with the people living in that service, build a picture & relationship with them to see if things are beginning to change. Will be used in their inspections as part of the process = not specially selected. Very interesting

Action: ask providers for views on all of these.
  • VCOD emergency access – what does this mean? CQC trying to keep it at the discretion of the RM – health emergencies & safety emergencies
  • Notification re workforce pressures – talk to LA partners first & then notify the CQC if struggling to resolve.
  • Registration – issues with the quality of applications; the process is being perceived as really inconsistent & being rejected out of hand – or the info is provided – and then yet more information is being sought. Plea for consistency & thoroughness
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