Following CQC’s suspension of routine inspections at the start of the pandemic and the implementation of the Emergency Support Framework (ESF), CQC has now started its next phase of regulation with the implementation of its “transitional regulatory approach”, starting with adult social care services and dental services.

CQC has stated that, whilst its focus will still be on the immediate risks from the pandemic, future monitoring of services will also look at areas where quality needs to improve. In summary, CQC states that areas of focus will be based on existing KLOEs, with better direct contact with people who use services, and more targeted inspection activity where concerns are present. On-site inspections will continue to be used where there are concerns that people are not getting good care and pilots are also being carried out to explore new ways of gathering evidence without being physically present at the service. After reviewing monitoring information and using the streamlined set of KLOES, a judgment will be made and if CQC is confident that there are no risks to people, no further action will be taken. Where there are concerns and this leads to an inspection of the service, inspections will be more targeted and focused on areas of risk. Inspections may not, therefore always lead to a change in rating of a service and CQC intends to provide further clarity in this respect in due course.

In view of this, providers should expect the need to provide a broader range of information to CQC and whilst inspections are likely to increase, these will continue to be based on areas of risk and routine inspections are unlikely to resume in the near future, if at all.

In our experience, we have started to see evidence of an increase in responsive inspections and follow-up inspections for services rated ‘Requires Improvement’ or ‘Inadequate’ prior to the pandemic, with criticisms being made of services for many aspects of care, not just those deemed as high risk. For example, providers are being criticised for training being overdue, there being a lack of stakeholder feedback, and staff supervisions being overdue. Whilst we do not seek to undermine the importance of such aspects, it is apparent that when CQC is undertaking an on-site inspection, its remit remains broad and will not be limited to areas perceived to be ‘at risk’.  Providers should therefore be mindful that whilst CQC is generally inspecting under a ‘streamlined’ set of KLOES, all aspects of care may well be considered and providers should be prepared for this.

CQC is also now considering its future strategy and whilst a full public consultation is planned for January 2021, stakeholder view are already being sought. Providers should therefore seek to be involved in this process if they wish to share any views.

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