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The Care Quality Commission (CQC) is preparing to make significant changes to the way it assesses health and social care services in England.
For care providers who have spent the past few years adapting to the Single Assessment Framework and Quality Statements, the latest proposals may feel familiar.
Key Lines of Enquiry, commonly known as KLOEs, are returning as part of a wider overhaul of CQC's assessment approach.
However, this is not simply a return to the old inspection system.
CQC is developing a new, sector specific assessment framework for adult social care which will retain some familiar elements of the current system while changing others significantly.
So, what is changing and what should care providers be doing to prepare?
Yes, although they will form part of a new assessment framework rather than simply reinstating the previous system.
CQC has published draft sector specific assessment frameworks covering adult social care, mental health care, primary care and community services and hospitals.
Within these new frameworks, the current Quality Statements are set to be replaced by Key Lines of Enquiry.
These will be structured questions designed to provide greater clarity about what CQC will consider when assessing a service.
For many experienced care providers, the terminology will therefore be familiar. However, providers should not assume that preparing for the new framework simply means returning to their old KLOE documentation.
The new KLOEs are being developed as part of a broader change to CQC's regulatory approach.
Why is CQC changing its assessment framework again?
The Single Assessment Framework was introduced with the intention of creating a more consistent way of assessing different types of health and social care services.
It retained CQC's five key questions but replaced the previous KLOEs with Quality Statements.
CQC has subsequently reviewed its regulatory approach following feedback from providers, stakeholders and independent reviews of its effectiveness.
One of the major conclusions has been that a single framework covering very different types of health and social care services does not always provide the sector specific clarity providers need.
CQC is therefore proposing separate assessment frameworks for the main sectors it regulates.
For care providers, this means there will be a dedicated Adult Social Care Assessment Framework.
No.
The five familiar key questions will remain at the heart of CQC assessments.
CQC will continue to consider whether a service is:
Safe
Are people protected from abuse and avoidable harm?
Effective
Does people's care, treatment and support achieve good outcomes, promote a good quality of life and follow appropriate evidence?
Caring
Are people treated with compassion, kindness, dignity and respect?
Responsive
Are services organised so that they meet people's needs?
Well led
Does the leadership, governance and culture support the delivery of high quality, person centred care?
These five areas will continue to provide the overall structure for assessments, with the new KLOEs sitting beneath them.
Under CQC's proposed new approach, Quality Statements will be replaced by KLOEs within the new sector specific frameworks.
Quality Statements were introduced as part of the Single Assessment Framework and set out the commitments CQC expected providers to meet.
The proposed KLOEs instead take the form of structured questions that describe what inspectors will look for during an assessment.
The intention is to make expectations clearer for both providers and inspectors.
This should give care providers a more transparent framework against which they can review their service, identify weaknesses and demonstrate good practice.
Another significant proposed change is the return of rating characteristics.
CQC's familiar four point ratings scale will remain:
Rating characteristics are intended to provide clearer descriptions of what care at each of these levels looks like.
This is potentially an important development for providers.
Understanding what CQC considers "good" is useful, but providers also need to understand what distinguishes a Good service from an Outstanding one, or where shortcomings could move a service towards Requires Improvement.
Clearer rating characteristics should help providers assess their own performance against those different standards.
CQC has proposed moving away from the numerical scoring methodology introduced alongside the Single Assessment Framework.
Instead of relying on individual numerical scores to calculate ratings, CQC intends to place greater emphasis on evidence, rating characteristics and professional judgement when reaching decisions.
The intention is to provide a more holistic assessment of the quality of a service.
For providers, this makes the ability to demonstrate consistently good practice particularly important.
Policies and procedures remain essential, but inspectors will also want to understand how those policies translate into people's actual experiences and outcomes.
CQC is moving away from the concept of one assessment framework applying across all of the sectors it regulates.
Instead, separate frameworks are being developed for:
For care providers, the important development is the creation of a framework specifically designed around adult social care.
This should allow CQC to reflect the realities of delivering care across settings such as residential care, nursing care, domiciliary care and supported living more effectively.
Absolutely.
Although the terminology and assessment structure are changing, people's experiences and outcomes remain central to CQC's approach.
Providers should therefore avoid viewing the return of KLOEs as simply a documentation or compliance exercise.
CQC will continue to look for evidence that demonstrates what care is actually like for the people receiving it.
That means providers need to be able to evidence good practice through areas such as:
The strongest evidence is not simply that a policy exists, but that it is understood, implemented and producing positive outcomes.
This is an important point for providers.
The new Adult Social Care Assessment Framework is currently being developed and CQC has published a draft framework as part of its consultation and engagement process.
CQC has said that the draft frameworks will be refined, tested and piloted.
Providers should therefore continue working to the current CQC assessment requirements until CQC formally introduces the new framework.
The return of KLOEs should be viewed as an upcoming change to prepare for rather than an overnight switch back to the previous system.
There is no need for providers to completely redesign their compliance systems immediately.
However, this is a good opportunity to review how effectively your service can demonstrate the quality of care it provides.
Providers should consider:
Until CQC confirms implementation arrangements, providers should continue to understand and evidence compliance against the current assessment requirements.
Familiarise yourself with the proposed KLOEs
Understanding the direction CQC is taking will help your organisation prepare gradually rather than having to react when the framework changes.
Review your evidence
Ask whether you can demonstrate that policies and procedures are working effectively in practice.
Could your team confidently evidence good outcomes if CQC visited tomorrow?
Review governance arrangements
Good governance should allow managers to identify issues before they become regulatory problems.
Audits, action plans, incident reviews, complaints, staff feedback and quality monitoring should form part of an ongoing improvement process.
Test staff knowledge
Compliance should not sit solely with the Registered Manager.
Staff should understand the policies relevant to their roles and be able to explain how they keep people safe, support positive outcomes and respond when something goes wrong.
Look at your service through an inspector's eyes
Internal audits and independent reviews can help identify gaps that may be difficult to see when you are involved in the day to day operation of a service.
Finding and addressing weaknesses proactively is far preferable to discovering them during a CQC assessment.
The direction of travel should ultimately provide greater clarity.
The five key questions remain, people's experiences remain central and the familiar four point ratings system remains.
What is changing is the structure underneath them.
Sector specific frameworks, KLOEs and clearer rating characteristics should provide providers with a better understanding of what CQC expects and how the regulator reaches its judgements.
However, a change in framework also creates a period of transition.
Care providers will need to understand both the current requirements and the direction of the new framework while CQC completes its development and implementation.
Preparation should therefore start with understanding your own service.
Where are your strengths?
Where are your risks?
Can you demonstrate that your policies are working?
Most importantly, can you evidence consistently safe, effective, caring, responsive and well led care?
At Quality Care Group, we work exclusively with the care sector and understand that effective risk management extends far beyond arranging insurance.
Our specialist team works with care providers to identify potential risks, strengthen governance and help organisations become more resilient.
Through our risk management services, including our Proactive Risk Audit and Mock CQC support, we can help providers identify potential gaps and areas for improvement before they develop into more serious problems.
As CQC develops its new Adult Social Care Assessment Framework, we will continue to monitor the changes and help care providers understand what they mean in practice.
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If you would like to review the risks within your care service or understand how Quality Care Group can support your organisation with CQC preparation and wider risk management, speak to our specialist care team.
Being prepared isn't simply about getting ready for the next inspection.
It's about building a safer, stronger and more resilient care service.
