Things are changing fast at the Care Quality Commission (CQC) this summer. In the light of previous negative publicity there is a new structure and a new approach developing. CQC say that by October there will be a new inspection methodology in place, so inspectors will be looking for different things and writing different reports.
The big news for the substance misuse sector is that all treatment services, whether residential or community services, will be based within the hospital directorate; more specifically within the section of this directorate that deals with ‘community based services for people with mental health needs’. This means that there should be a similarity of approach to community drug and alcohol services and residential rehabilitation services.We wait to see whether this means that the methodology being developed will be more similar to clinical treatment services than adult social care. For a long while residential services battled to be thought of as ‘treatment services’ rather than ‘care homes’, so maybe this will lead to a more realistic and ‘joined-up’ approach to inspection?
Another piece of good news is that CQC has appointed a ‘national professional advisor and policy manager for substance misuse’. Her name is Violeta Ainslie and she used to work as treatment provider with Cranstoun Drug Services until very recently. I am personally very encouraged on two counts. Firstly, this is a full-time post dedicated to this sector. In my previous role, the substance misuse sector was only a small part of my job; now there is someone dedicated to the sector, who can join up all the dots within CQC and be a point of reference for external agencies. Secondly, as someone who was recently working within the sector, she is well placed to understand the unique characteristics of substance misuse treatment.
Part of the national advisor’s role will be to set up an ‘expert group’, which will be a reference point for the development of the new methodology for this sector. At the time of writing, this group was due to begin its deliberations at the beginning of July. The next step will be publishing a ‘signposting’ document which will chart the way forward and explain when the new methodology is likely to be implemented. So, while the adult social care sector is planning to implement in October 2014, the substance misuse sector may have to wait a while. The message is, ‘watch this space!’
Having completed the first consultation phase on 4 June, in which CQC tested various elements of the new methodology in hospitals and care homes, CQC will now no doubt use some of the feedback and incorporate it in the new approach to the substance misuse treatment sector.
New Methodology
There is no doubt that the new methodology will focus on the ‘five questions’, which are: Is the service safe, effective, caring, responsive and well led? You may have seen the provider handbooks and appendices on the CQC website, which set out the proposed framework. There are some key features which mark a change from the previous approach:
• The ‘provider information return’ will be sent out to services before the inspection, so that they can self-assess against the five questions.
• There will be ‘key lines of enquiry’, which will act as prompts to inspectors as they look at how the five questions are worked out in the service.
• There will be ‘ratings’ which will be published and will determine inspection frequency. These ratings extend from ‘outstanding’ to ‘good’, then ‘requires improvement’ and finally ‘inadequate’. There are complicated rules which determine how these rating are arrived at – however there are also helpful guidelines that tell you what each rating might look like for each question.
• There will be a greater reliance on ‘experts by experience’ to provide the service user perspective.
• There will be an emphasis on ‘intelligence monitoring’, which means gathering information from a range of stakeholders.
• Finally, although the Care Act 2014 has been granted Royal Assent, the new draft ‘fundamental standards of care’ and ‘regulated activity regulations’ are now awaiting parliamentary approval so cannot be enforced until that is achieved. It is expected that this will happen by October 2014 so that the new approach is fully grounded in law.
Meanwhile, between now and October 2014 CQC will continue to undertake routine inspections, so if you have an unannounced inspection this will be according to the existing methodology. There will be one difference and that is that the summary at the beginning of the report will focus on the ‘five questions’ as a taster of what is to come. The possible reasons for an inspection before October are: that your last inspection occurred between April and October 2013; there are outstanding compliance actions; there have been complaints made to CQC which they may be following up in terms of compliance; or you have changed registered manager in the last 12 months.
When looking forward to the new approach, some of the most recently published inspection reports give clues as to what may be asked. However it is worth waiting to see exactly what is proposed for the substance misuse sector and, where possible, contribute to the debate through routes such as FDAP and your representatives on the ‘expert group’.
As CQC publish more information, such as the ‘signposting’ document with an outline of their new approach, it will be possible to look at the implications for your service more fully. To help this process there will be courses which will focus on the substance misuse sector this autumn, organised through DDN.
David Finney is an independent social care consultant. His course on everything you need to know about the new structure is on 6 November in central London.