We're changing the way we regulate, inspect and rate health and care services. Please tell us what you think of our plans.About this consultation:We want to find out what people think about how we're planning to change the way we regulate, inspect and rate care services. The changes include things like:what we look at on an inspection.how we judge what 'good' care looks like.how we rate care services to help you judge and choose care if you want to.how we use information to help us decide when and where we inspect.What changes are we proposing?The main changes are:
- introducing new ways to inspect services, with Chief Inspectors and more specialist teams that include members of the public.
- using a new system of intelligent monitoring to help us decide when, where and what to inspect.
listening to people's experiences of care and using the best information across our monitoring system.We plan to base our judgements and ratings based on the five key questions we ask of all services:Are they safe?Are they effective?Are they caring?Are they responsive to people's needs?Are they well-led?How we developed the changesWe developed the changes outlined in these documents over the past year together with the public, providers, our staff and organisations with an interest in our work.The changes were originally signalled in our three-year strategy in April 2013 and we developed our thinking by setting out some initial proposals in a series of Fresh start documents.We've also been testing our new style inspections in hospitals, mental health and community health services. We will be testing them in adult social care services and GP practices from April 2014.Our final plans will be developed using the feedback from this consultation and will be published in September 2014. The changes will come into effect in October 2014.
Royal College of Physicians of Edinburgh Response to the CQC Consultation on how we regulate, inspect and rate services
The Royal College of Physicians of Edinburgh (“the College”) has 50% of its UK Fellows and Members working in the NHS in England, and is pleased to respond to the CQC Consultation on how we regulate, inspect and rate services. This response relates to the NHS acute hospitals provider handbook.
1. In addition to inspecting core services, we are also considering focusing on specific patient groups during an inspection, for example people with a learning disability, mental health condition, diabetes or dementia. We would assess whether the provider understands and meet the needs of these specific groups.
Do you agree that this is the right approach?
The College agrees with this approach, which will test the horizontal structures and processes in a Trust. By specifically focusing on the most vulnerable groups, care is likely to be improved for all patients.
2. Do you feel confident that the key lines of enquiry and the list of prompts will help our inspectors judge how safe, effective, caring, responsive and well-led NHS acute hospitals are? Is there anything we are missing?
Yes, but these are fairly detailed, and Trusts may not have the infrastructure in place to satisfy these key lines of enquiry. This should be monitored to see how Trusts are able to respond.
We have provided examples of evidence we may collect during our inspections. Do you agree that this is the right kind of evidence for us to look at? Is there other evidence we could use?
The College feels the examples of evidence suggested are appropriate.
3. Do you agree that the characteristics of ‘outstanding’ (in appendix C) are what you would expect to see in an outstanding acute hospital service?
Yes.
Do you agree that the characteristics of ‘good’ (in appendices B and C) are what you would expect to see in a good acute hospital service?
Yes.
Do you agree that the characteristics of ‘requires improvement’ (in appendix C) are what you would expect to see in an acute hospital service that required improvement?
Yes. However, the College feels there should be a further category of “satisfactory”, as there is a large jump from “good” to “requires improvement”. Categories should be tightly defined.
Do you agree that the characteristics of ‘inadequate’ (in appendix C) are what you would expect to see in an acute hospital service that was inadequate?
Generally, yes. However it is important to have a balanced approach – for instance, a staff member being rude would place the service as inadequate for caring, even if this were an isolated event. There is a need for proper triangulation of evidence.
4. Our key lines of enquiry, prompts and ratings characteristics are generic. Do you agree that they can be applied to all of the core services?
Probably, although this should be monitored and evaluated to ensure these are appropriate and work in different circumstances.
Do you feel confident that a generic approach covers the issues most important for each core service? Is there anything missing?
The inspection process has some flexibility and there will be an iterative approach for some time. Specific new issues can be incorporated if required.
5. We want to know whether you agree with our approach to human rights. Please see our separate human rights approach document, in which we are asking a number of questions. We would also like your comments on our equality and human rights duties impact analysis.
No specific comments.
6. How best do you think we can ensure that providers improve the way they conform with both the wider Mental Capacity Act and the Deprivation of Liberty Safeguards?
At this stage the College suggests that inspection could focus on individual case histories and the general Trust approach.
Make sure we give sufficient weighting to this in our characteristics of good?
No specific comments.
b) If providers do not meet the requirements of the MCA and the Deprivation of Liberty Safeguards, apply limiters (meaning a service could not be better than requires improvement) in a proportionate way to ratings at key question level?
No specific comments.
c) In other ways?
No specific comments.
7. During our inspections of NHS acute hospitals, we will use a number of methods to gather information from the public about their views of the services provided.
Do you agree that the proposed methods of doing this are the right ones to use? Will they enable us to gather views from all of the people we need to hear from?
The College feels this is a fairly comprehensive approach. However, it may be difficult to get a balanced perspective as the patient/carer groups would be self-selected, and using a web based system may disadvantage certain members of the public, such as older people or people with learning difficulties, who may have pertinent observations to make about their care but have difficulty accessing and using online forms.
8. Are there ways in which we could promote learning between providers and services, particularly where we have identified outstanding care?
The College suggests a CQC website which captures and promotes examples of good practice.
9. Do you agree that the grounds on which trusts can challenge their inspection reports and ask for a review of their ratings?
Generally yes. Trusts must be able to give informal feedback at the time of the draft report and to provide clarification on any areas of uncertainty.
10. Do you agree that providers should be able to apply for a single focused inspection to recognise where improvements have been made?
Yes. However, the inspectors should consider whether the service they are inspecting is dependent upon other areas. For example, medical core services will be affected by the quality of emergency department services.
11. Do you agree that the five key questions are equally important and should be weighted equally in our aggregation method?
Yes.
12. Do you agree that in general the core services should be weighted equally, the only exception being where a core service at a trust is particularly small?
Yes.
13. Do you agree with the guidelines for aggregating ratings? Are there any that you disagree with? Is there anything else that we should include?
Yes.
14. Do you agree that CQC should use key pieces of information as described? What pieces of information would you recommend that we should use?
Yes.