Understanding the CQC's new single assessment framework

As all health and social care providers will be aware, the Care Quality Commission (CQC) has now implemented its new single assessment framework with assessments being undertaken across England.

Since its initial inception, there have been a number of reported issues with its implementation, as well as delays, and it has received an array of criticism across the sector. Whilst some providers have welcomed the change, many providers initially found the guidance confusing and difficult to navigate and experienced significant difficulties with the provider portal.

Additionally, it is clear that there is still some further refinement and guidance needed, particularly around the frequency of assessments. Previously, inspections followed an inspection schedule which was determined by the previous rating of a service, whereas the new framework allows for judgements and ratings to be updated without the need for a full inspection, meaning that ratings should be more up-to-date. However, the exact frequency of inspections is not yet clear, although the CQC have indicated that they plan to share more detail on how they plan to increase the number of assessments in due course. In the meantime, this remains a real concern for providers still rated as ‘requires improvement’ or ‘inadequate’ who are awaiting re-inspection.

Previously, the CQC operated two separate assessment frameworks, one for healthcare services and the other for adult social care services. However, this new single assessment framework now applies to all providers, local authorities and integrated care systems regulated by the CQC. It has made significant changes to how the CQC now inspects, scores and rates all services and it is therefore important that all providers are aware of how this framework operates and its key changes, before they are assessed under this framework.

Key changes under the CQC’s single assessment framework

The CQC’s new assessment framework is still based on the five key questions which existed under the previous frameworks, namely:

1. Is the service safe?
2. Is the service effective?
3. Is the service caring?
4. Is the service responsive?
5. Is the service well-led?

Quality statements

Each of the key questions now has a set of quality statements, replacing the Key Lines of Enquiry (KLOE’s), prompts and ratings characteristics, which existed under the previous framework.

The quality statements are expressed as ‘we statements’ and the new assessment framework outlines what is expected of providers in order to deliver safe, high-quality and person-centred care under each quality statement. However, the various areas assessed under each key question remain the same. It also sets out the relevant fundamental standards of care under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 which are relevant to each quality statement. The framework also makes reference to the best practice guidance which the CQC expect providers to be aware of and follow under each quality statement.

The CQC have set out six evidence categories which it will focus on when assessing a quality statement, which are:

1. People’s experiences
2. Feedback from staff and leaders
3. Feedback from partners
4. Observation
5. Processes
6. Outcomes

For each evidence category, the CQC sets out a definition and examples of the types of evidence it will look at and this could be gathered on or off site. The number of evidence categories considered for each quality statement and the sources of evidence utilised will vary depending on the type of service and assessment.

One of the key elements of the previous assessment framework which remains the same is that adult social care providers will still be asked to complete an Annual Provider Information Return (PIR).       

Ratings and scoring

Under this new single assessment framework, the CQC have retained the previous ratings of outstanding, good, requires improvement and inadequate. However, there is now a scoring system, which assists the CQC in determining the ratings for each key question.

The CQC state that the introduction of this scoring system will support the transparency and consistency of their judgements and enable it to see if quality or performance is moving in the right direction within a rating. For instance, whether a service is the higher end of a rating threshold and nearing the next rating or vice-versa.

So, how does it work? When assessing evidence, the CQC will assign a score to each evidence category under a quality statement, all of which are then combined to give an overall score for the quality statement in percentage terms.

The scores range from 1 – 4 and are summarised as follows:

It is important to note that all evidence categories and quality statements are weighted equally. In order to calculate the percentage score for the quality statement, the total number of evidence category scores are divided by the maximum possible score (i.e. the number of relevant evidence categories multiplied by four, the highest score for each category). This percentage is then converted back to a score in line with the following thresholds:

The next step is to calculate the rating for a key question from all of the quality statement scores. This is done by calculating a percentage score for all of the evidence category scores combined. This is done by calculating the total score of all evidence categories and dividing it by the highest possible score (4) across all categories. This percentage is then converted into a rating in line with the following thresholds:

However, there are certain ratings limiters and principles which apply and can limit individual key question ratings or overall location ratings.

Calculating the first scores and ratings

For any services that have not previously been inspected or rated by the CQC, all quality statements in a key question will need to be assessed by the CQC before a rating can be published. The CQC’s stated approach is to assess all quality statements within a newly registered service within 12 months of their new registration.

For existing providers with already published ratings under the previous assessment framework, any quality statements reviewed will be scored based on the evidence collected in each relevant evidence category. Not all quality statements may be looked at and this will be determined by a number of factors, including national priorities dependent on the type of service and information currently held about the service. Scores for any remaining quality statements will be based on the CQC’s previous findings, however, the date of the CQC’s assessment will be provided alongside each quality statement so this is clear. This scoring is subject to various exceptions and guidance, as outlined within the new framework.

Following this, scores for each individual evidence category can be updated at various times throughout a provider’s period of registration, as the CQC will now be assessing different areas of the framework as appropriate on an ongoing basis, as opposed to just at one particular moment in time, as was the case previously. Any changes in evidence category scores will then update a quality statement score. The combined quality statement scores then create a rating for the relevant key question.

Contact our specialist CQC solicitors

Our specialist lawyers have extensive experience of successfully challenging inspection reports and ratings, achieving an increase in individual and overall ratings and the removal of regulation breaches. You can read more about how to challenge a CQC inspection or assessment report or rating here.

If you have received an assessment under the CQC new single assessment framework and you wish to challenge the CQC’s findings, judgments, scores or ratings, you can contact our specialist CQC solicitors now for a confidential, no-obligation discussion on 0161 696 6250 or via our online enquiry form.