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It is really encouraging to see CQC develop the Single Assessment Framework (“SAF”) in response to feedback.

A number of care providers have services which had been rated Requires Improvement or Inadequate at inspections prior to the introduction of the SAF – in many cases, those ratings dating back to 2019 or earlier. With the roll out of the SAF, we have been assisting clients to raise their significant concerns following their first CQC SAF assessments, during which CQC only focussed on 7 to 10 Quality Statements, meaning that their ratings have not changed, despite significant improvements being noted.

This is because the first scores calculations, when considered alongside such a small number of Quality Statements, rendered it mathematically impossible to improve their rating, even if the assessments of those Quality Statements were positive.

On the 26th March, Ian Trenholm, CQC’s Chief Executive, published a blog which included the following: “Every service is different, of course, and so the amount of work required to confirm or change a rating will vary depending on the starting position. When carrying out an assessment of a service that is either inadequate or requires improvement all quality statements under the key question that are rated inadequate or requires improvement will be reviewed. It has always been true that a provider with many key questions rated as requires improvement will require significantly more work to re-rate as good than one key question rated as requires improvement. That does not change in the new approach, though the amount of work per key question rating is reduced. Our new approach gives us the opportunity to do that work in smaller packages of work over shorter time frames, working on and off site, which providers will find less disruptive.”

Services with an existing overall rating of Requires Improvement or Inadequate can now expect CQC to assess ALL the quality statements for EACH of the key questions previously rated as Requires Improvement or Inadequate.

This is great news and presents an opportunity for those services which have yet to be assessed under the SAF, and whose businesses have been affected by historical ratings which were less than Good overall. It also means that these services now know that CQC will be assessing at least those Quality Statements as a minimum, so they can consider what evidence they may like to present to CQC in advance of their assessment.

It is hoped that, in time, CQC goes further and that this is a starting point for CQC to re-consider how it chooses which Quality Statements to assess and whether the SAF reports as published are reflective of a service.

One of the wider issues is where services are rated as Good overall with one key question which was historically Requires Improvement, but at the point of their SAF assessment CQC chose not to assess those quality statements. There have already been SAF reports published which are Good overall but where the Well-led key question retains its Requires Improvement rating from a 2019 inspection with an updated date of the 2024 assessment.

It is disappointing that the new CQC portal has had so many challenges and that the rollout has not gone as planned, it is encouraging that CQC have been quick to acknowledge this and let’s hope that ‘portalgate’ is resolved soon!

The SAF does represent an opportunity for CQC to assess differently and has a lot of potential, it is hoped that over time this also includes accurate date labelling, appropriate transparency of judgements and fair opportunities for ratings to be changed.


Our team of specialist care solicitors support providers in navigating the CQC changes. You can join our mailing list for further updates here or get in touch to discuss how we can help you on 01202 786135 or