CQC’s Transitional Regulatory Approach and IPC from October 2020: constant change, or change is a constant?
Anyone working in health and social care for more than a few years is aware that we keep changing, developing and moving the goal posts in response to what we learn or to ever-evolving circumstances. However, the CQC’s fundamental standards, key lines of enquiry and methodology had settled down and has been feeling familiar over the past five years.
Well change is afoot! In response to Covid-19 and the general direction of travel towards a more intelligence-led regulator, the CQC is adapting. They have publicly said they will not be returning to their usual schedule of pre-pandemic inspections. For now, and likely until their new strategy kicks in in March 2021, they will be using two main tools to assess compliance against the Health and Social Care Act and regulations, although they have said their purpose has not altered.
Infection, Prevention and Control
The Infection, Prevention and Control (IPC) tool replaces much of the emergency support framework that was introduced by the CQC in May 2020 at the height of the pandemic when very few inspections were taking place due to the risk of spreading infection and is being rolled out after an initial pilot.
It will focus on infection prevention and control, safety and leadership. Inspectors will visit and use prompts around:
- safety of environment
- premises and equipment
- infection control
- safe admissions and discharges
- use of PPE, testing, hygiene and policies.
A report will be published on the CQC website (you can see some examples by region here), but no rating is given or changed as a result.
There appear to be three measures which are published:
- Somewhat assured
- Not assured.
These inspections are focused and will only be expanded if serious risks are identified during the visit. CQC ratings can only change if two or more key areas are inspected.
Transitional Regulatory Approach
The Transitional Regulatory Approach will be a desk-top assessment by inspectors. They may also contact managers and providers to ask specific questions or to request specific pieces of evidence. They will then use all the available intelligence about a location/service to assess the risks, helped by an algorithm.
The results of the TRA desk-top exercise will not be published. If there are low risks and no concerns, only a summary will be shared with the provider. If the results of the TRA show a high level of risk, a focussed inspection will be triggered soon afterwards. Again, a rating will not change as a result of a TRA unless a focussed inspection covers at least two key areas.
The intention is that every service will go through the desk-top TRA, but this will only lead to an inspection in the higher risk services or at the lower end of ‘requires improvement’ (multiple breaches) or inadequate, or when CQC becomes aware of concerns in a service rated good or outstanding. This means it is likely to be a very long time yet until some good services are revisited.
Lobbying to improve your CQC rating
For services who were rated “requires improvement” last time with one or two breaches and who feel they have improved and would now be rated good if inspected, I can see frustrations and anger as, again, the wait for a re-rating inspection may be considerable.
I would recommend staying in contact with your inspector and periodically tell them about what you have done to improve – either regarding infection control or concerning people’s quality of life – and supporting this with pertinent and relevant evidence. I would also recommend informing your commissioners by letter that you no longer feel your ‘requires improvement’ rating is an accurate reflection of the quality of service you provide. It’s also a good idea to keep telling the public about your improvements on your website.