How to Prepare for a CQC Reassessment Under Returning to Good
Preparing for CQC’s Returning to Good Approach
For some adult social care providers, six or seven years may have passed since their service was last assessed and awarded a CQC Good rating.
A lot can change during that time.
Leadership may be different, staff teams may have changed and the needs of the people using the service may have evolved. Providers may also have introduced new systems, governance processes and ways of working.
CQC’s Returning to Good programme is designed to establish whether ageing Good ratings still accurately reflect the quality of eligible services today.
For providers that may be reassessed under the programme, CQC inspection preparation should therefore focus less on recreating the conditions of a previous inspection and more on understanding the service operating now.
Understand What CQC’s Returning to Good Programme Is
CQC is returning to eligible adult social care services currently rated Good to confirm whether those ratings remain accurate.
The programme focuses particularly on services with ageing ratings where CQC considers a Good rating likely to be maintained.
This is a more streamlined approach than CQC’s usual assessment process. It initially considers 18 CQC Quality Statements and places increased emphasis on people’s experiences and outcomes.
Inspectors will use conversations and observations of care alongside proportionate checks of records and other evidence to reach their judgements.
For providers, this means preparation needs to extend beyond documentation.
The quality described within policies, audits and care plans should also be evident in everyday practice.
Check Whether Your Service Could Be Eligible
Not every service with an older CQC Good rating will automatically be reassessed through Returning to Good.
CQC has established specific eligibility criteria.
Services considered through the programme must:
- be rated Good overall
- be rated Good across all five key questions
- generally have a rating at least six or seven years old
- have a registered manager
- present no indication that the rating has changed
- not provide care or treatment to children
- meet CQC’s criteria relating to services for autistic people and people with a learning disability
- have no ongoing enforcement activity
The approach can apply to care homes, including residential and nursing services, supported living services and homecare services where the eligibility requirements are met.
Providers should therefore check the current CQC Returning to Good guidance rather than assuming that the age of their rating alone determines eligibility.
Start with the Service You Operate Today
An older inspection report is useful context when preparing for CQC reassessment.
It should not, however, become the sole basis for preparation.
Consider what has changed since CQC last assessed the service.
A new registered manager may have been appointed.
The staff team may be substantially different.
People’s needs may have become more complex.
Care planning systems may have changed.
Governance arrangements may have developed.
The service may also have experienced safeguarding incidents, complaints, staffing pressures or other challenges from which lessons have been learned.
The relevant question is therefore not simply:
Was our service Good when CQC last assessed us?
It is:
Would the evidence and practice within our service today still support a Good judgement?
Review the 18 CQC Quality Statements
CQC’s Returning to Good approach initially focuses on 18 CQC Quality Statements across the five key questions of Safe, Effective, Caring, Responsive and Well-led.
Under Safe, these are:
- Learning culture
- Safeguarding
- Involving people to manage risk
- Safe and effective staffing
- Safe environments
- Medicines optimisation
Under Effective:
- Assessing needs
- Delivering evidence-based care and treatment
- Monitoring and improving outcomes
- Consent to care and treatment
Under Caring:
- Kindness, compassion and dignity
- Independence, choice and control
Under Responsive:
- Person-centred care
- Listening to and involving people
- Equity in experiences and outcomes
Under Well-led:
- Shared direction and culture
- Governance, management and sustainability
- Learning, improvement and innovation
These Quality Statements provide a useful framework for CQC inspection preparation.
However, providers should avoid treating them as 18 isolated compliance exercises.
Quality runs across the service, and a single area of practice may provide evidence against several Quality Statements.
Remember That CQC Can Expand the Assessment
The 18 Quality Statements are the starting point rather than an absolute limit.
If CQC identifies concerns or evidence of outstanding practice during its planning, it can expand the assessment to include additional Quality Statements.
Where this happens, CQC will return to its usual published assessment approach.
Providers should therefore avoid preparing narrowly for the 18 statements while overlooking wider areas of quality, safety or governance.
The stronger approach is to use the statements as a framework for examining whether good practice remains consistently embedded throughout the service.
Look at the Service Through the Experience of People Using It
One of the most significant features of Returning to Good is the increased focus on people’s experiences and outcomes.
CQC says its assessors will spend more time gathering feedback from people using the service, visitors, visiting professionals, staff and leaders.
Where possible, they will also observe care and support in practice to understand what people’s everyday experiences are like.
For providers, this means looking beyond what a care plan says should happen.
Consider what people actually experience.
Are individual preferences reflected in day-to-day care?
Can people make meaningful choices?
Do people feel listened to?
Is independence encouraged appropriately?
Can people raise concerns and feel confident they will be taken seriously?
Is the care being delivered consistent with what has been agreed?
A service may have strong documentation, but CQC will be interested in whether those commitments are visible in practice.
Consider What Your Staff Would Tell CQC
Staff and leaders are another important source of evidence within the Returning to Good approach.
Preparation should not mean coaching staff to provide particular answers.
Instead, providers should consider whether there is a genuine and consistent understanding of how the service operates.
Staff should understand areas such as:
- safeguarding responsibilities
- risks relating to the people they support
- people’s preferences and individual needs
- consent and capacity
- medicines responsibilities where relevant
- escalation processes
- how incidents and concerns are reported
- what the service has learned when something has gone wrong
A strong service should not require staff to memorise responses before CQC arrives.
Their answers should naturally reflect the practice, culture and expectations they experience every day.
Where staff understanding differs significantly from what policies or leaders describe, that is an area worth identifying before CQC does.
Observe What Happens in Everyday Practice
Policies describe how a service intends to operate.
Observation can reveal whether that intention consistently reaches the people receiving care.
This makes everyday practice particularly important when preparing for CQC reassessment.
Consider ordinary situations within the service.
How are people’s choices responded to?
Do staff understand the risks recorded in care plans?
Are people supported at the time they need assistance?
Is dignity maintained during personal care?
Are medicines procedures followed consistently?
Do staff respond appropriately when somebody’s needs change?
Does management challenge poor practice when it is identified?
These observations can provide a very different level of assurance from simply reviewing documents.
Check That Care Records Match What Actually Happens
Documentation remains part of CQC’s evidence gathering.
Under Returning to Good, CQC says record and document checks will be proportionate, targeted and informed by what inspectors hear and observe.
That makes consistency important.
A care plan may describe one approach while daily records indicate something different.
A risk assessment may identify controls that staff cannot explain.
An audit may show an issue as complete while the same problem continues to occur.
Providers should therefore look at the relationship between:
- assessments
- care plans
- risk management
- daily records
- staff knowledge
- observed practice
The objective is not merely to establish whether evidence exists.
It is to determine whether that evidence accurately reflects how care is being delivered.
Review Whether Governance Provides Genuine Assurance
Governance is one of the 18 CQC Quality Statements included in Returning to Good.
It is also fundamental to whether leaders genuinely understand the quality of the service they are responsible for.
Under Regulation 17: Good governance, providers are required to operate effective systems and processes to assess, monitor and improve the quality and safety of services, including people’s experiences.
These systems should also identify and manage risks and support continuous improvement.
Providers preparing for reassessment should therefore consider whether their governance arrangements provide meaningful assurance.
Do audits identify important problems?
Are actions followed through?
Can leaders identify recurring themes across incidents, safeguarding and complaints?
Does senior management understand where the greatest risks currently sit?
Can the organisation demonstrate that improvement actions have actually worked?
Governance should help providers identify weaknesses before an external regulator needs to point them out.
Look at Learning Rather Than Simply Recording Incidents
Two of the CQC Quality Statements included within Returning to Good are Learning culture and Learning, improvement and innovation.
That makes the response to problems just as important as recognising that they occurred.
Incidents, complaints or safeguarding concerns do not automatically mean that a service cannot remain Good.
The important question is what happened afterwards.
Providers should be able to demonstrate:
- how immediate risks were managed
- whether the cause of the issue was understood
- what was learned
- what changes were introduced
- whether those changes were followed through
- whether improvement was subsequently checked
- whether learning was shared where appropriate
An action plan provides evidence that an organisation intended to make a change.
The stronger evidence is being able to show that practice genuinely improved as a result.
Ask Whether Your Evidence Provides Assurance
Evidence and assurance are not the same thing.
A training record demonstrates that a member of staff attended training.
It does not automatically demonstrate competence.
An audit proves that a check took place.
It does not automatically demonstrate that a problem was resolved.
A reviewed care plan demonstrates that somebody updated a document.
It does not automatically prove that care remains personalised.
Providers preparing for CQC reassessment should therefore look beyond whether documents can be produced.
Ask instead:
What does this evidence actually tell us about the quality people receive?
That shift from checking evidence to testing assurance is particularly important when CQC itself is placing increased emphasis on people’s experiences and observed practice.
How Can a Mock CQC Inspection Help?
Providers do not have to wait for CQC to return before finding out how current practice may stand up to external scrutiny.
A mock CQC inspection can provide an independent view of current compliance and help identify gaps that may be difficult to see from within the organisation.
Fulcrum Care provides comprehensive Mock CQC Inspections designed to assess services against the current CQC framework.
A meaningful mock inspection should look beyond whether the required documents exist.
It should test whether governance, records and leadership expectations agree with what is happening throughout the service.
For a provider carrying an ageing CQC Good rating, this can provide useful assurance about whether the standards reflected in that rating remain embedded today.
When Might a Remote Mini Mock Inspection Be Useful?
Not every provider will require a comprehensive on-site mock CQC inspection.
Fulcrum Care also provides a Remote Mini CQC Mock Inspection, which offers a more focused review of selected compliance documentation.
Providers can submit evidence such as care plans, staff training records, policies and procedures for independent review.
Fulcrum then provides feedback on areas of strength alongside recommendations where improvement may be required.
The service is specifically positioned for providers that want to assess CQC compliance, prepare for an inspection or help maintain an existing positive rating.
For stable services looking for a proportionate external check, this can be a useful starting point.
However, CQC’s Returning to Good approach gives significant weight to people’s experiences, conversations and observation.
Where a provider wants a fuller assessment of how quality presents itself in everyday practice, an on-site mock CQC inspection may provide greater assurance.
Do Not Prepare Staff to Perform for CQC
Good CQC inspection preparation should strengthen the service rather than create an artificial version of it for assessment day.
Staff should not need scripts.
Documents should not suddenly tell a different story because an inspection is expected.
Leadership should not become visible only when CQC announces a visit.
The strongest position is one in which everyday practice already demonstrates the standards the provider expects.
An independent mock CQC inspection can be particularly useful when it assesses the service as it genuinely operates.
Any gaps identified can then be addressed through meaningful improvement rather than short-term inspection preparation.
Preparing to Maintain a CQC Good Rating
Returning to Good places an important question in front of providers with ageing ratings.
Would the service operating today still support the Good judgement CQC made several years ago?
Preparing for CQC reassessment is therefore not simply about understanding the 18 Quality Statements.
It means looking at people’s experiences.
Listening to staff.
Observing everyday practice.
Checking whether care records reflect reality.
Testing whether governance gives leaders genuine assurance.
For providers wanting an independent view, Fulcrum Care’s Mock CQC Inspection and Remote Mini CQC Mock Inspection services can help assess current CQC readiness and identify where further action may be needed.
If your service has held a CQC Good rating for several years and you want to understand how current practice may stand up to reassessment, contact Fulcrum Care to discuss the appropriate level of mock inspection support.