VODG responds to Care Quality Commission strategy consultation

VODG has today submitted a response to the Care Quality Commission’s (CQC) formal consultation on its draft strategy

The draft strategy has been developed to “enable more effective regulation for the future and support services to keep people safe” and is built on four themes: people and communities, smarter regulation, safety through learning and accelerating improvement.

Key points raised in the submission, include:

• The ambitions of the new strategy, and the four themes that sit under it, are to be welcomed. If the ambitions are achieved, they have the potential to bring about a cultural change in the way CQC, as well as providers, operate. There is, however, a significant gap in how things are currently working and the ambitions of the new strategy which needs to be planned and managed through strong partnerships. 
• There is much for CQC to consider in making the rhetoric of its new strategy a reality while also confronting the impact of the coronavirus (COVID-19) pandemic has had on the people and families supported by social care services as well as to the workforce.
• In order to fulfil the ambitions around health inequalities, it will be critical for CQC to recognise and involve the various bodies that have a fundamental role, alongside providers, in helping to tackle health inequalities. This includes strong and active engagement with the voluntary sector.
• A key factor in achieving the ambitions of the strategy will be an acceptance of, and for some, a willingness to change amongst the CQC workforce. Consistency in the implementation of new ways of working will also be crucial
• If the role of CQC is to be enhanced as proposed in the government’s Health and Social Care White Paper and for it to hold a greater oversight role of systems, there is an argument for greater scrutiny around value for money delivered by CQC. The enhanced remit of CQC should not be funded through provider fees.
• A move towards greater focus on regulation that is driven by people’s needs and experiences of health and care systems is positive and strongly aligned with the ethos of VODG members. There is, however, concern around how the process will work in reality and how accessible it will be to meet the needs of working age disabled adults.
• There is currently no national CQC definition as to what constitutes a ‘strong safety culture’ and this needs to be developed, in consultation with people who use services, providers, commissioners and other stakeholders and then used to help guide assessments in this area.
• There is a need for CQC inspectors to recognise, and where appropriate report on, wider organisational initiatives that are aimed at preventing issues around safety and not focusing solely on incidents and / or problems.
• In order for CQC to support and drive best practice among providers, then providers also need best practice commissioners who commission at best practice rates. It will be helpful for CQC to have some level of scrutiny or insight into how local commissioners work and how the services being assessed are commissioned.

The VODG submission also outlined a series of recommendations:

• CQC to publish criteria for success and to ensure absolute clarity and transparency around provider fees.
• CQC to review use of inaccessible and jargon-heavy language in its final strategy.
• CQC to undertake regular stocktakes on the implementation of its strategy, including with the voluntary disability sector. The results of these stocktakes to be published.
• CQC inspectors ask providers for feedback about how well the inspection experience matched the new strategy at the end of each inspection.
• In implementing more dynamic and flexible regulation, it is imperative that checks and balances are integrated into the system to ensure a proportionate response in the public interest.
• Strategy delivery plans should include mechanisms for providers to evidence their work around safety and prevention.

Dr Rhidian Hughes, Chief Executive of VODG said:

“The test of the strategy will, however, be in its delivery on-the-ground at a time when voluntary sector providers are operating and carrying out activities that are above and beyond their contracted duties. We look forward to continuing to work in partnership with CQC and will take review with our members as to how well CQC’s new strategy is being implemented.”