January’s CQC trade association meeting covered some useful topics. See slides: January Trade Association Meeting Notes
Recent Publications
Welcome – Rob Assall
Note – On Thursday, CQC will publish their next Operational inspection update – will continue to inspect based on risk & based on building capacity in the sector
Public Engagement Strategy – Jill Edemenson
Share objective & ambitions for the strategy
Aiming to improve the way they engage with & involve the public
Progress since 2017 – better channels for communication, external strategic advisory group meetings, new online platform – Citizens Lab; Give Feedback on Care & new public payments policy to support public engagement; evaluation – awareness survey & national Stakeholder Sentiment Survey
What’s next? Involving people right from the start, feedback loops need improving
4 Core Objectives:
- An inclusive public listening service
- Accessible public info service
- A fair inclusive approach to involving people who use services
- Working in partnership with organisations who represent people
The presentation looked at the inclusive public listening service and provided more detail on the accessible public info service. It also included more detail a fair & inclusive approach – a wider range of people, including those at risk of poor health outcomes, better feedback to track impact, improve insight sharing.
There was a focus on working in partnership – better transparency & openness, focus on the seldom heard. The presenter also introduced the feedback that had been received so far.
Discussion
NCF points: Key for us are the CQC’s limited ability to influence choice. There is huge anxiety about the balance of feedback to the CQC – there is no mention here of positive as well as negative and how the balance will be managed ; there is no mention of the voice of providers; it seems to ignore the principle from Quality Matters that providers have a key role in being the first point for feedback; it is very opaque & there is not openness on how this engagement intelligence it fits into the whole algorithm approach; there is no recognition of the constraints of commissioning; it seems unable to account for the impacts of future reform – e.g. the care cap & potentially unrealistic expectations from the public of what this will actually change for them.
CQC response: Public experience framework – more detail on the principle & frameworks on how planning to gather experience & how to manage the balance of this – will bring it back to a session at the Trade Assoc Meeting –see Public Experience Framework subsequently shared post meeting.
Plus the LA assurance framework will include clear feedback from providers.
NCA: how will providers be listened to? Need transparency in how the data is interpreted.
CQC: the frameworks will set out how CQC will use & receive data & how to analyse and apply it in future. Keen to work with providers to showcase how they listen. Very keen to hear about good practice
Q: What happened to the QM approach of providers fixing it first? CQC would want to speak to the provider first to solve it, depending on the issue; but don’t want to discourage people reporting to the CQC as well though
Homecare Association: balance is key; if the issue is actually down to commissioning practice & if the provider cannot do anything about it, then the balance is not fair if the provider gets the flack & the LA doesn’t!
CQC: they want confidence in the public sharing their issues with the provider, including any anxiety about any possible impact on their care ; we must all build trust
Operational Update – Alison Murray
Continue to inspect, prioritising risk, freeing up capacity, using IPC tool & looking at workforce
VCOD#1 – inspecting since 11 Nov, running a panel to assess breaches of the regulations to ensure consistency & oversight. Had 16 breaches reported since 11 Nov. 50% pitched at requirement level type action & CQC is confident they can be resolved, 4 had warning notices due to greater concern; others are having significant enforcement and these are services with lots of other concerns & VCOD breach only a small part of it.
Members will note that added standard wording on VCOD to the inspection template report
VCOD#2 – some of this came into play from 6 Jan – new starters 21 days after 1st jab & follow up in 10 weeks. Go live for the rest of it on 1 April. Guidance took a while, now gone out – read it carefully; Extra guidance is due on the delay to the vaccine because of having COVID – 28 day delay . Webinars planned – one on Thursday, one next week – SfC – on Weds; Also FAQS planned.
CQC approach likely to be same as VCOD#1; proportionate approach.
***** POST MEETING Note – the DHSC has announced its plans to revoke all the VCOD regulations; this is in train but has not yet happened. ****
VCOD#2 Grey areas: CQC cannot make the decision for employers; depends on the shade of grey. Expect majority of staff will be straightforward; for the grey areas, providers must risk assess, discuss, document & keep under review – hopefully that will be sufficient for any inspector queries
What about those working in QA roles in services? Depends how is it done – if the roles go out to sample provision of care in face to face settings may be in scope; if done virtually then not
Issue of CQC inspectors not evidencing their vaccination status? Please tell them
Other things:
Visiting: still a lot of concern & generating a lot of work. CQC is expecting to go an oral JCHR evidence session soon. Had lots of info about impact of local system decisions, outside DHSC guidance. Yes, there will be instances where local HP teams give advice outside the guidance for all sorts of good reasons – if care home shuts a home to all, then they should do it in conjunction with local system.
*****POST MEETING NOTE – the guidance has changed again****************
Care Hotels: CCGs are using empty care homes to accommodate people and using live in carers, with staff deployed at distance & not having suitable oversight; this is creating issues within health & social care & the media is interested; CQC looking into it in terms of who is commissioning what & the quality of care being provided; they know it is out there, causing concern & if providers are taking on this activity, do tell your inspector as they are doing calls with dom care providers.
Exit interviews: CQC is very concerned about workforce pressures, wider operational pressures & providers exiting the market; CQC keen to understand why providers are choosing to voluntarily exit from the market; planning a quick pilot to contact providers who have submitted registration cancellation requests & ask them some questions before they cancel & getting more insight into why – what could be done earlier? CQC cannot track those choosing to temporarily mothball services – but all ideas welcome
See Exit Interview questions shared post meeting & the Workforce question they are using
Freedom to Speak Up Freedom to Speak Up Guardians, and the National Guardian’s office – Russell Parkinson and Dr Jayne Chidgey-Clark (freedom to speak up in the NHS)
First discussion on this with the sector & they are in listening & planning mode; there is a White Paper commitment to the Freedom to Speak up in social care
Russ Parkinson – Head of National Guardian’s Office
- What does speaking up mean & what gets in the way? It is a gift but it requires a growth mindset; organisations and managers need to hear the things we don’t want to hear and it is much better to know about an issue even if it is uncomfortable. It includes anything that gets in the way of great quality & safe care, including having a good experience at work. It should not be a problem for the person who wants to speak up – organisations & managers should enable listening & action if needed.
- The issue is more about the barriers people encounter – the example of the Mid Staffs & Gosport hospital scandals – people did speak up & suffered as a result
- Barriers to speaking up – huge cultural shift was needed in health. Barriers = not worth their while, things don’t change, people who do suffer, professional hierarchy & seniority
- The National Guardian’s Office – what they do: they lead the network of Freedom to Speak Up Guardians to challenge & support the healthcare systems as a whole. The guardians are recruited in their organisation, the National Office will train & support & lead them
- The guardians are an additional route but have to work in their orgs to make it better / easier to speak up; it’s a complicated job. They report to their boards regularly
- Jayne is new in post; the ASC White Paper includes a commitment to a pilot of Freedom to Speak Up Guardians, in collaboration with the National Guardian’s Office. Huge opportunity.
- General principles: don’t want to make any assumptions about how it works in ASC – how does Speaking up work now? What’s already happening? What from the health model can help? What can’t? What are the barriers? How can it work across a mixed model of providers & services? How can they co-create it?
Discussion
Q: re: Issues re confidential disclosures;
A:the NHS guardians will negotiate about this with people who come forward and it also needs a leadership commitment to the issue raised, not the person raising it;
Q: ESL also an issue for some A: in the NHS, there are assumptions about language competency
Q: Resourcing? A: No answers – NHS pays for it in their trusts – not a full time role, but do have protected time; relatively easy for large organisations; primary care organisations sometimes club together to share a guardian role
CWC: care workers want to speak up on issues they face; but routes are limited beyond their employers – some face issues with colleagues, issues with abuse from those they support- would there be a helpline? What is the model of intervention? A: the National Guardian won’t offer a helpline – already a helpline
Offered the CPA route to engage – Chidgey-Clark, Jayne: enquiries@nationalguardianoffice.org.uk
Local Authority Assurance Scope of assessments – Jeanette Blackburn and April Cole
The scope of the framework still in progress. There was a recap of the single assessment framework – 5 key questions, underpinned by the quality statements – the ‘we’ statements
We can only include the Care Act duties for LAs to go in the assessment framework.
The pillars for the assessment framework
- Working with people – assessing needs (including unpaid carers), supporting people to live healthier lives, prevention, well-being information and advice
- Providing support – markets (including commissioning), workforce equality, integration and partnership working
- Ensuring safety – safeguarding, safe systems and continuity of care
- Leadership and workforce – capable and compassionate leaders, learning, improvement, innovation
Each of the themes has several quality statements and ‘I’ statements within it
Slides then look at the 4 pillars in detail & the quality statement underpinning it
Discussion:
Q: Where is Fair Cost of Care? CQC: It’s in market shaping section
Q: Do the I statements work? Recipients are seen as the customer & the I statements have value – BUT can you make a causal link between the LA behaviour & the experience for the person? That relationship is more with LAs & providers – the causal link between individual experience is more with providers. This framework must be more robust to hold LAs not fulfilling their duties in the Care Act – it’s clear that the Care Act has not been delivered – the WP says so – & there must be accountability.
Q: Missing – where is the wellbeing of people who deliver care & support? Where is the ‘the I statement about I am confident that the people who support me are well looked after’?
Lots of support for the 4 pillars & key themes but need a focus on outcomes & impact; and more focus on empowering not supporting. What about the discharge procedures & what it means for people?
How LAs use Direct payments? How to challenge reduction in funding? Is this in scope
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