The CQC is due to implement their new assessment framework, complete with six new evidence categories. These six categories are used for each individual Quality Statement (QS). All services will then be able to see exactly what they’ve scored out of 100% within each of the QSs. This is excellent news because it makes the whole process transparent and clearer than the previous system, which simply informed services of their rating (x5) for the KLOEs and then an overall rating.

Once it’s implemented, if you have a couple of staff who haven’t completed their fire safety training, for example, you’ll be able to see exactly what that has cost your service in terms of your score and rating.

It also means you’ll know exactly where you need to consider challenging findings/facts in CQC reports because you’ll be able to see precisely what scores you need in order to get the ratings you desire. This seems pretty positive, but we know that sometimes the outcome might not be what you’d expected – so, what do you do about it? It’s time to challenge the facts!

Factual Accuracy Challenges (FACs) are the two-week window that services get to respond to draft CQC reports. They’re sent to the inspector who visited your service, and you can attach any evidence you have to support your challenges. Currently, it isn’t clear who will review the FACs under the new CQC structure, but the principles should be the same.

Under the current rating system, it’s tricky to know what, if any, impact a FAC can or does have on a CQC report. Although the CQC responds to FACs and always states whether each individual challenge has affected any ratings, the responses are vague and impossible to really question (sigh!).

Current FAC process – an example 

Imagine you get a draft report with Requires Improvement in Safe because as the report and evidence table state: We found that several staff had not completed recommended training.

You challenge this finding with evidence to show that, although you didn’t have the evidence on the day of the inspection, all of your GPs have completed the recommended training and have their certificates.

The response from the CQC in the FAC states: Although you have provided evidence to demonstrate that the GPs have completed their training, three receptionists had no evidence of having completed the training. Therefore, the rating will remain the same.   

You’re still rated Requires Improvement despite your evidence that the number of staff without training was very small.

Safe and Effective Staffing – QS within Safe example continued 

Under the new system, you’ll get a score for this QS out of 4 (4 being the best). So, if you’ve received a 2 on the basis that the majority of your staff haven’t completed recommended training, you’ll be able to challenge this with evidence in a way that could and should change your score. If you can demonstrate, with evidence, that the majority of your staff have completed training, then it will be much harder for the CQC to refute this or refuse to increase your score and potentially your rating.

This same logic will apply throughout the report and rating process. For every QS, you’ll know precisely what score you’ve achieved, and why, in all 34 QSs which form the five domains. This precise methodology becomes even more effective when applied to PMS data, such as cancer screening or childhood immunisations. If the CQC award one service with a certain score based on their data, then it will struggle to deviate from that same score for another practice. This could be a good thing or a bad thing depending on how you view it.

If one practice is scored badly for having 20% of patients on high-risk medicines who have not had sufficient monitoring, will all services with that same data receive the exact same score? The CQC will be able to monitor data on systems like EMIS live AND alter ratings/scores based on it. The crucial thing to remember is that the data is controlled by practices primarily, and now practices can see what score that data results in with the CQC.

I’m optimistic that this change will bring about improved transparency and increased challenge from all stakeholders involved.