Care Quality Commission
Wednesday, 5 December, 2012

We were created three and a half years ago. Since then we have introduced a new regulatory system and new standards for 40,000 organisations that provide health and adult social care. The new standards focus on people’s experiences and put their rights and interests at the centre of our work.

We play an important role in driving improvement in the quality of care people receive in hospitals, in care homes, from care providers in their home, from dentists, and, from next year, from GPs. Others who play an important role are the organisations that provide care, frontline professionals and staff, organisations that commission care, economic and professional regulators, and the people who use care services.

Since 2009 there have been important changes in the economy, in government policy, in technology and in society that affect our work and mean we must review what we do and how we do it. We’ve also listened to, and learned from, comments made by the Health Select Committee, during the public inquiry into Mid Staffordshire Hospital, and by others. We expect the report of the public inquiry to be published during our consultation. We will review our strategy in the light of the inquiry’s conclusions and recommendations.

In the past few months we have discussed our ideas with hundreds of people, including our staff, members of the public, organisations that provide care, other regulators, voluntary organisations, the Government and the main organisations we work with in the health and care system.

Comments on Care Quality Commission Consultation on Strategy for 2013-2016

The Royal College of Physicians of Edinburgh (the College) is pleased to respond to the Care Quality Commission’s Strategy Consultation 2013-2016.  The College has the following comments:

The College agrees that the use of accurate information and evidence to inform decisions is essential.  It is therefore vital that data collection is optimised as care will need to be taken to ensure that the information gathered is reliable and robust.

The College supports the Care Quality Commission’s (CQC’s) aims to be flexible and tailor their approach to different services and organisations.  There is potential to learn from other regulators in this regard, using information from their own records and from publicly available sources, to establish and learn from good practice.  It is crucial that the regulators co-ordinate to avoid unnecessary duplication of demands and to prioritise information capture.

The College welcomes the constructive approach in this regard, providing that it leads to better co-ordination between regulators and a reduction in duplication of assessment and administration.

The College feels it is not yet clear how the CQC’s relationship with the Commissioners or with Local Education and Training Boards (LETBs) will develop.  We would welcome more detail on this aspect as these relationships will have a significant impact on training.

The College does not feel it is clear how complaints from service users and their carers are to be facilitated, recorded and collected, and how the CQC is to be made aware of complaints.  We would appreciate clarification on this subject and particularly if this is to be part of the review of each provider to enable certification against required standards.

It is vital that CQC is seen as objective and fair by care providers.  The College would welcome a more constructive role for the CQC with regards to hospital care.  To develop respect and credibility among providers will require the CQC to develop accurate data, evidence based guidance and to ensure that their inspectors are adequately trained and supported to carry out their tasks.  The CQC must also be seen to be independent of government.

The CQC has described the financial pressures facing Health and Social Services over the coming years.  Therefore if a service fails due to inadequate funding, the CQC should be explicit about the reasons behind the failure.

No comment.

The College feels it would be useful for CQC to analyse its impact and effectiveness in terms of outcomes rather than processes.  Measuring factors such as improvements in mortality, treatment effectiveness, patient safety and satisfaction between monitoring visits would be examples of outcomes that would provide meaningful data for analysis.

This process of becoming a high-performing organisation will be evolutionary.  Tackling all aspects of the large and all-encompassing remit would be a high risk strategy, and therefore CQC should build up its work streams over time.  Early success in high impact/profile areas will be key to delivering sustained improvement and should determine priorities.

  1. What are your views on us making greater use of information and evidence to guide us in regulating services, which may mean we regulate different services in different ways?
  2. What are your views on our approach to managing our independence and working with our national strategic partners and other organisations? Does it strike the right balance?
  3. What are your views on our approach to building better relationships with the public?
    The approach seems very sensible: improved communication is crucial to progress in this area.  Currently there is a perceived lack of knowledge about the CQC within the general public and potential for misunderstandings through high profile media coverage.  The CQC will only build better relationships with the public if there is an improved communication and education programme.
  4. What are your views on our proposed approach to tackle complaints?
  5. What are your views on whether our proposals will build respect and credibility among providers?
  6. What are your views on our approach to strengthening how we meet our responsibilities on mental health and mental capacity?
  7. What are your views on how we might most effectively measure our impact?
  8.  What are your views on our proposal to become a high-performing organisation? Are there other factors that we need to take into account?