It is without doubt that at the time of writing (28 June 2024), CQC find themselves in hot water. Ian Trenholm’s rather sudden departure had been anticipated given the turbulent manner in which the Single Assessment Framework (SAF) has been implemented.

Mark Topps has written an excellent article reminding providers about the importance of sustainability within Social Care. It points providers to some valuable resources and is a useful reminder of the importance of being prepared for the future. It is not certain if and when this quality statement will be implemented, but what is apparent is that it is something on CQC’s radar and it is worth providers taking some time to put arrangements in place.

Over and above the recommendations he makes, I wish to stress the importance for providers at this time of going back to the regulations and ensuring full compliance with them.  

It is apparent that the implementation of the SAF has been woefully inadequate. The Health Service Journal have reported that CQC have admitted that it is failing to keep people safe and is losing the confidence of stakeholders. This follows on from the announcement in May 2024 that Dr Penny Dash will be leading a review of CQC’s effectiveness.  

With the regulator currently fundamentally unable to fulfil its statutory functions, the situation is reminiscent of a class with a supply teacher. A handful of studious types will be carefully ensuring compliance, whereas the majority of the class will see it as a reprieve from regulation and let things coast along as they are. A small proportion will see it as an opportunity to play up and refuse to engage with the system. This is of great concern to me.  

It is important to stress that the regulations underpinning the framework have not changed. The onus will be on providers to ensure that they are compliant with the regulations in order to keep service users safe.

The sector has strived in earnest to navigate the implementation of the SAF. My experience has been that the SAF has led to assessment reports that are repetitive, confusing and not representative of the current situation at a service. Not enough quality statements have been reviewed and there is an over reliance upon Assessors or Inspectors attributing numerical values to their findings. Historic findings are being relied upon too heavily are significantly influencing outcomes.

Furthermore, all factual accuracy checks are being completed on the portal. Just the mere mention of the CQC Portal fills me with dread. It is a system not fit for purpose. Many providers have quite rightly pointed out that if they had systems in place like that, they would be deemed inadequate. When completing a Factual Accuracy check, the amount of time it takes to go to the review your responses page is astounding. I have waited over five minutes in some cases. Attaching evidence is fraught with difficulties and there is a strict word limit. We are experienced at dealing with these reports and if you find yourself in that position we would be happy to assist.

My hope is that providers take the initiative in this uncertain time and they ensure that they are compliant with the regulations and are pro-active in future planning with a focus on keeping service users safe.

www.gordonsols.co.uk

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