Next Phase

1. Routine re-inspections start all over again, and Providers will be expected to be better prepared.
2. Focused or targeted visits where there are specific concerns

You will be on the radar if:-

• Complaints are made against you
• Whistleblowing by employees who are concerned about your standards
• Whistleblowing by disgruntled ex-employees
• Serious incidents that warrant attention
• Entire Groups, Federations, Franchise operations: If your members expose systemic faults
• Note: Changes in Registration details may reclassify you as a "new" uninspected location

 When was your last inspection?

Your next inspection will depend on the date of your last one.
2013 to 2015: A re-inspections is an almost certainty.
2016: Re-inspection cycle has started.
2017 and 2018: Poor clinical performance and smaller Providers puts you at risk

Whistleblowing, incidents and complaints pose the highest risk in triggering an inspection.
Groups need common standards and quality management to avoid inspections escalating into a wider investigation.
Franchise operations face a particular level of risk.

This is a high risk category due to the volume and nature of services, subject to higher scrutiny and almost 50% have already undergone multiple inspections.

Providers with only one inspection so far and poor clinical performers are at the highest risk of an inspection

Less than 10% have had a second visit.

Providers inspected in 2015 and 2016 are prime targets for a re-inspection.

Whistleblowing, incidents and complaints pose the highest risk in triggering an inspection.

Map of inspection stages

1st Stage: Fundamentals

• Have you got basic rules for operating the organisation
• Is everyone aware of the rules
• Do you record activity

2nd Stage: Operations

• Record of activity, and completeness
• Basic staff competency, recruitment processes and appraisals

3rd Stage: Monitoring

• Staff training and development, awareness of key safety areas, knowledge
• Management competency, Good governance, oversight of operations

4th Stage: Care

• Governance and accountability of officers
• Standards of care, Involvement in care, Consent

5th Stage: Actual Performance

• Engagement with stakeholders, joined up care
• Outcomes achieved, comparisons and benchmarks

Final Stage: Maturity

The CQC is moving towards online self-declarations and targeted site visits. The old PIR (Provider Information Request) will be replaced with an annual online Provider Information Collection report (PIC).

CQC will target Providers based on their declarations and intelligence gathered from other sources. Whistleblowing will become more important in trigger inspections.

Future: CQC becomes part of the NHS

The CQC is likely to reinvent itself and may seek a change in legislation. The transformation has already started:-

1. Inspect all providers [done]
2. Extend to inspect owners of Groups [2018/2019]
3. Extend to inspect Complex Providers [2018/2019]
4. Invent NEW role: Inspect CCGs and Commissioning [In motion since 2014]

“….. we need to be able to look at how the system operates, not by being invited to do reviews but in it being part of the routine way we do our business. I think that requires legislative change.”

Sir David Bevan

May 2018

This process started in 2014

According to an interview given by Sir David Bevan on 20^th March 2015, the process started 12 to 18 months before that interview.

The CQC is looking to become an “embedded regulator” in the system and commissioning so that they inspect 24/7/365 from inside the system instead of being “invited to inspect”.

In essence, CQC will become internal auditors, and part of the NHS and yet independent from other employees, thus guaranteeing its survival for as long as the NHS exists.

Expert in a single day:

1. If you are already familiar with the old system, all you need to read are the actual Quality Statements pages.
2. Ignore the Regulations and Best Practice as you will already be familiar with this
3. Ignore the scoring system, this is for the inspectors to rate their findings, you have no control over this until an actual inspection/assessment

Key takeaways for the Single Assessment Framework

2 to 5 year transition period

1. SAF is being introduced in a phased approach, with partial audits for up to 5 years
2. Full transition from old KLOE reports to Full SAF audits is likely to take 5 years or more

Don’t waste time on learning the scoring system

1. Subjective – hard to anticipate
2. Hybrid system, inspector can add new checks
3. Under review by Government – might change yet again

There are 15 Frameworks

1. 15 Sectors each with a custom framework
2. Cannot compare providers in the same sector OR between sectors
3. The scoring system will mean very little to providers

One rule for inspectors another for Providers

1. Inspector can do a partial inspection ranging from 1% to 100% of the evidence categories
2. BUT you still have to prepare for 100% of the  204 categories just in case

Same same but different

1. KLOEs : Hundreds of measuring points, impossible to check in a short 1-2 day inspection, so every inspector had their own mini-checklist
2. Single Assessment Framework: Same potential problem, different list