CQC consultation: Have your say!

Don’t miss the chance to change CQC inspections, says David Finney.

The Care Quality Commission (CQC) has recently issued a consultation on changes to the inspection of independent healthcare services, and this includes substance misuse services. The consultation has a deadline of 23 March 2018 for responses and is available here. In my view it is urgent that substance misuse services participate in this consultation, otherwise a key window of opportunity will be lost to influence the practice of the regulator.

The consultation document and previously issued Key lines of enquiry for healthcare services (July 2017) contain very little mention of substance misuse services at all, suggesting that they are being overlooked within regulation.

While CQC still publishes some ‘brief guides’, these mostly relate to detoxification services rather than other residential or community services. In practice there are regional leads for substance misuse services, but below that level the experience of inspectors is variable, so there is a danger of inconsistency in inspections. Specialist professional advisors have been used alongside inspectors, but the overwhelming majority have been nurses or doctors with experience of NHS settings rather than independent residential or community services. Once again, it seems that residential rehabs, in particular, are being marginalised within regulation.

The new approach has positive and negative aspects for the substance misuse sector – however, a key problem at present is lack of engagement with the sector by CQC corporately. A report highlighting the failings of detoxification services has been published (30 November 2017), but no other recognition of the residential rehabilitation services has been forthcoming. When substance misuse services were regulated within the adult social care directorate of CQC, many providers felt that they were not understood by the regulator.

To avoid substance misuse services becoming marginalised within regulation once again, providers need to make an active response to this consultation. The sector should come together and lobby CQC to help it to become the informed and proportionate regulator it aims to be.

Key features of the consultation

CQC say that the aim of their new approach is to be ‘targeted, responsive and collaborative’. They propose that some key developments will be:

a. Unannounced or short-notice inspections:
an initiative to be launched in April 2018. This will be a change from the current practice of giving long notice for announced inspections and mean that providers will not have the opportunity to organise the day so that they can present their service to the inspection team. Neither will they will be able to arrange for service users to be available to speak to the inspector, apart from by taking them out of their existing programme commitments at short notice.

b. A new model for collecting data, called CQC Insight. This seems to match the type of data collection used by the NHS, but may prove difficult for smaller residential services that do not have the data systems available to larger corporate bodies.

c. Rating of services. The characteristics for rating services defined in the assessment framework (KLOE) are very general, and do not reflect what a ‘good’ or ‘outstanding’ substance misuse service looks like. There is the possibility that services may be rated according to the subjective view of the inspector, rather than a recognised benchmark.

d. Changed frequency of inspections: so that outstanding services are inspected every five years, good services every three and a half years, services requiring improvement every two years and inadequate services every year. There is also a provision for ‘special measures’, which will lead to more intensive monitoring. I have two major concerns for services awarded a lower rating: if there is a long time before another inspection, this may adversely affect the availability of the service to local authority funded placements and the business overall; and secondly, it is likely that services will not be able to admit new service users, which will very quickly undermine the business financially and not allow it to recover.

e. Effective use of accreditation schemes. In contrast, this is an opportunity for the sector, because CQC say that these schemes could shorten inspections or even replace them altogether. Although previous accreditation schemes for this sector have fallen by the wayside, this is a new chance to focus on the distinctiveness of substance misuse services.

f. Relationship management. This is about the development of strategic planning and the encouragement of improvement within the sector. Some larger providers already have a relationship manager within CQC, but this function has been inconsistent across the country. So the challenge is to regularise the arrangement so that all providers have the advantage of access to this service.

g. Emphasis on well-led domains. Good leadership and governance is clearly important; however, aspects which tend to feature highly in the consultation are document-based factors such as quality assurance systems and methods for implementing lessons learned. These are relevant, particularly in corporate bodies, but it is equally important to recognise the impact of management, which is in regular informal contact with service users and their progress through recovery.

David Finney is an independent social care consultant who has worked with government inspection bodies

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