The Care Quality Commission is once again changing the way it inspects and rates substance misuse services. Make sure you are prepared, says David Finney.
The Care Quality Commission has released a new strategy, Raising standards, putting people first – our strategy for 2013–2016, and it could have major implications for the substance misuse sector.
Recent reports from Mid Staffordshire, Winterbourne View and the Health Select Committee have all been critical of CQC and its operations. Internally, CQC has commissioned two reports which have also set challenges, such as the restoring of ‘star ratings’ and an overhaul of its methodology. So what are the changes we should look out for?
CQC now seems to have ended its generic approach to regulation. The commission says that there will be new ‘fundamental’ care standards, differentiated by sector, with specialist teams to inspect hospitals and social care services. The health secretary, Jeremy Hunt, has announced that CQC will also reintroduce ‘performance ratings’ so that the general public will have good information on which to base their choices of services. CQC also says that it will inspect services according to risks posed to people who use the service – an ‘about turn’, after recently committing themselves to annual inspections.
Other significant changes will be the appointment of a chief inspector for hospitals, as well as chief inspectors of social care and primary care. CQC has been quite open about its priorities, saying that ‘the changes will come into effect in NHS hospitals and mental health trusts first, because we recognise that there is an urgent need for more effective inspection and regulation of these services.’ It goes on to say that ‘we will extend and adapt our approaches to other sectors in 2014 and 2015.’
The immediate questions for the substance misuse sector regarding this ‘direction of travel’ are:
• How specialised will the inspection approach be, ie will substance misuse be seen as a ‘stand alone’ sector?
• The substance misuse sector is comparatively small, so how can it be heard in the consultation process on the new standards and the new methodologies?
• Will there be an opportunity to contribute to the training of inspectors in the particular knowledge and skills necessary to inspect the substance misuse sector?
• What will the performance ratings look like, and will they reflect how excellence is perceived in the substance misuse sector?
My view is that the ‘big players’ in the sector and the representative bodies need to ensure that they are in communication with CQC at an early stage so that their voice is heard. There is also no harm in single providers making representations to be included in the consultation process, because CQC says that it is committed to working with partners in the health and social care system.
Another interesting strand to the CQC strategy is the desire to listen to people who use services. CQC says that it will focus on gathering the views of people in the most vulnerable circumstances. There is also a specific point under the heading of ‘Involving people in our work’, which says that: ‘We will set up a panel of people who use services to inform all aspects of our work and improve how we gather the views of the people who use services.’ CQC also says that it ‘will improve how we involve small and diverse community groups in our work.’
These seem to me to be great opportunities for service user representative groups to get in touch directly with CQC and raise issues on behalf of people who use substance misuse services. And remember this includes many community services which are registered with CQC as well as residential services.
The next and most immediate question is: what can we expect in the coming year?
The public statements of CQC are that it will be ‘business as usual’ for the social care sector. This means that the approach outlined in Improving the way we regulate, (a document published in February 2012), still applies. This means that you will be inspected on at least five outcomes, one from each of the chapter headings in the ‘Essential standards’. The intention of CQC was to cover all 16 outcomes in a three-year period, so it is likely that the outcomes inspected will be different this time around.
A reading of inspection reports shows that CQC tended to look at the following outcomes most often during the last round of inspections in 2012-13:
• Respecting and involving people who use services – 1
• Care and welfare – 4
• Safeguarding – 7
• Supporting workers (supervision and training) – 14
• Monitoring of quality – 16
So for the forthcoming year, as providers, you need to look at your last inspection report and check if these outcomes have been inspected. If any haven’t, then make sure you are up to speed and prepared for them. If they were inspected, then you need to look and see what CQC might prioritise next. In its documents CQC says that it will inspect according to information received, so if there have been any safeguarding issues raised or complaints passed onto CQC then these outcomes will be the first to be inspected. Also, CQC says that it tailors its inspections according to the services you provide, so the next priority may be other key components of the treatment you deliver. My suggestion is that the following might be high on CQC’s priorities if they haven’t been inspected already:
• Consent – outcome 2
• Medicine management – outcome 9
• Staffing – outcome 13
• Complaints – outcome 17
There has also been a growing tendency for CQC to ask about any people in your services who might temporarily lose capacity to make decisions where the requirements of the Mental Capacity Act 2005 become relevant.
The preparing of evidence for your inspection is important and needs to be well thought through. This will involve ensuring that relevant policies are up to date and that the approach you are taking matches that outlined in CQC’s ‘Essential standards’. It could also be crucial to prepare your staff, and people using your services, for any discussions they may have with the inspector, so they know what to expect and can answer the questions as openly as possible. Some providers have found an external audit very useful, both from the information gained and also the experience of being inspected on outcomes, with which they may not have been familiar.
My recommendations are that you get involved, be well prepared, don’t leave it to others, and ensure that service users are right at the heart of what you do.
David Finney is an independent social care consultant with a specialist interest in the regulation of substance misuse services and was formerly national lead for substance misuse services with CSCI.
He will be running a one-day course in partnership with DDN, on Tuesday 18 June, to look at the changes in detail. CQC compliance – whatever next? is at The Malmaison Hotel, Birmingham; email firstname.lastname@example.org or call 01233 636 188 for details.