Top tips for CQC assurance preparation

April 2023 is the expected implementation date of the new Care Quality Commission (CQC) Assurance framework. 

That date is approaching rapidly, and the time for preparation is now short. Councils are strongly encouraged to begin their preparation now if they haven’t already. You may also need time to address any gaps in your organisational or partnership infrastructure that have arisen around the new demands of integrated care systems (ICSs) and your local integrated care board arrangements. 

These nine top tips update the Northern ADASS Regions Top Tips originally published in May 2022, with many thanks to those regions, and reflect the focus of activity that Partners in Care and Health believes will help all councils to maximise their preparation in the coming three months of 2023.

Directors of Adult Social Services (DASSs) will want to be fully aware of the assessment process and requirements as they emerge from the Department of Health and Social Care (DHSC) and CQC. At the time of writing, CQC has yet to publish the final assessment framework but a new quality statement covering 'equity in experiences and outcomes’ will be included in the final version. There are likely to be other technical documents and briefings on the run up to April 2023 and the opportunity to take advantage of resources from the LGA and the ADASS Regions that will support local preparation.

The experiences of the two councils that have participated in the CQC ‘test and learn’ exercise have been that the process can be resource intensive, with the compilation of the CQC self-assessment and information return for just two Quality Statements taking nearly 30 days’ work for one of the test and learn sites. Having adequate co-ordination and oversight capacity to support the preparation process (and to support the assessment fieldwork when it happens) is therefore essential. 

Consider:  

• making preparation a key responsibility of a senior manager (eg Head of Service or Assistant Director if not the DASS) to lead on preparation for CQC assessment and the wider assurance process
• if any senior or project management recruitment is planned, build these responsibilities into new job descriptions
• establishing assessment preparation governance and resources and agree as early as possible what the key tasks are, for example:
  • completing the LGA self-assessment workbook
  • using other peer assessment processes
  • tapping into the regional ADASS assurance support offer
  • partner engagement and briefing
  • preparing ASC staff and keep them informed and involved
  • building up a portfolio of evidence to support the four CQC themes
  • preparing for potential case audit and other methods of active quality assurance
  • updating policies and procedures
  • developing an ongoing communications plan etc
• encourage and release time for your assessment and assurance leads to take part in regional activities such as performance benchmarking and peer reviews.

Take the opportunity to discuss with key elected members, especially any relatively new to the adult social care portfolio, the central themes of the Care Act 2014 that the CQC assessment process is designed to test out, including the overall spirit of the Act and its specific statutory requirements.  

• Provide regular briefings to cabinet on CQC expectations and how the council’s performance will be measured in key areas and the significant risks arising from any adverse judgements.
• Explain the early need for some dedicated workforce and system resources for the council to prepare thoroughly and effectively for the implementation of CQC assessment and assurance.
• Share the learning from your preparation process with key elected members (and the wider cabinet as required) and engage them in shaping the local ASC narrative that you will put forward during an assessment.

Responding to the new assessment and assurance regime will require support from the whole council.

• Secure the understanding and support of senior colleagues for the corporate services their teams may need to offer to ASC as part of the preparation, for example, communications, business Intelligence, learning and development, HR, finance, children’s services, public health.

Use available activity and performance data to inform your preparation, including service user and carer surveys, statutory data returns and the Adult Social Care Outcomes Framework (ASCOF) data, and compare with statistical neighbours and regional benchmarks. However, primarily focus on what your data tells you about care quality, impact, user and carer experiences and outcomes – not processes.

Use your data and engagement insight to support your evolving local narrative.  Where your performance shows room for improvement be open about this, show that you have analysed why and how you need to improve, and have a clear plan for doing this. Be aware that CQC will have interrogated six to 12 months of your data before they arrive on site.

• Check how well you currently gather ASC activity and performance data, and service user and carer feedback, and consider the quality and accuracy of your information.
• Think beyond service data - there are also likely to be service user and carer satisfaction, financial, workforce and complaints reporting requirements. Can you access and collate this information easily?
• Are you confident that your own data and intelligence is accurate and considered together does it portray a picture of ASC that is recognisable and explicable? 
• If performance data or service user feedback is directly linked to workforce issues, such as staff recruitment or specialist skills gaps, for example Approved Mental Health Professionals (AMHPs), be upfront about this and show how you plan to address this in the interim. 

Expect CQC to play the key role in assessing how well ICSs and councils engage their local populations and develop services in partnership to meet their needs.

Health partners and leaders should be appraised of the challenges and requirements of the CQC assurance framework, and know that they will need to provide performance, financial, and activity data for this purpose, especially where services are delivered through integrated funding and delivery arrangements. In some cases, they will need to jointly account for the overall performance and quality of their services, their strategic direction and improvement ambitions.

• Ensure formal notification to integrated partnership / organisation’s leadership via letter or agenda setting of the new assessment framework and its implementation date.
• Ensure they are fully engaged in the preparation process though regular agenda items, invitations to briefings, programme planning.
• Share an easily digestible written synopsis of your developing narrative and direction of travel with key partners – do not take it for granted that partners know or will remember your strategic aims or progress, especially new personnel within the integrated care arrangements. 

CQC has stated that there will be a focus on how the local system delivers and enables good outcomes at a population level, in line with the integrated service aims expressed in the Care Act; so expect care transitions, pathways, integration and unmet need to all be explored. However, also be fully prepared for CQC to primarily focus on the direct delivery of care and the regulatory and legal framework. Note that CQC’s vision is to become a data-driven regulator.

Joint DASS/Director of Children's Services (DCS) leads have reflected that both OFSTED and CQC assurance processes are equally rigorous, but outcomes and experience have traditionally carried more weight in the OFSTED process. How much emphasis CQC will place on the experience of service users and carers, compared to other types of evidence, is still unclear at this stage.

However, both test and learn sites noted CQC’s interest in co-production and citizen engagement/involvement – this covered how ASC consults, engages and co-produces with people who use services. At the very least, be able to describe your current ethos and approach to co-production.

• Find out what they do in children’s services, what people and systems they have in place and assume you will need to have something broadly similar to support ASC preparation for CQC assessment.
• Learn from how children’s services provide compelling evidence of the experiences and outcomes of children, young people and families, through both quantitative and qualitative methods, for example survey data, case studies, quotes, photos etc.

The CQC assessment is likely to look for evidence of collaborative and co-operative working relationships with partners, operationally and strategically, and will potentially comment on your organisational culture, as observed, or experienced by your partners.

Feedback from partners is one of six evidence categories that CQC will use to form their judgement. A range of statutory partners, providers and local strategic partners will be approached for their views on the council’s ASC performance. The voluntary sector, community organisations, Healthwatch and independent adult social care providers are all likely to be involved. You could also draw upon their insight as part of the preparation for assurance, particularly in areas they think the council should improve, or equally, where they recognise existing performance is of a high standard.

• Consider the existing meetings and forums where ASC managers can share details of the new assessment and assurance regime and/or provide written briefings and share your evolving performance and improvement narrative. 
• Explain the ‘asks’ that may be made of partners and providers during the assessment process.
• Plan to secure some systematic feedback from voluntary and independent social care providers and community organisations on the council’s ASC performance in areas where they will have an informed perspective – use these insights and views to inform your self-assessment.

Two areas that are expected to be important across the assessment as a whole are co-production and showing an understanding of people’s lived experiences, and equity of access, experience and outcomes – for both service users and carers.  Effective co-production can also support a better understanding of barriers to care, equity and outcomes.

Part of this is about knowing your place and community, informed by demographic and performance data, but also understanding which groups or communities are more likely to experience poor care and support.

This is not just about people with protected characteristics, it requires much broader thinking around people who are socially and economically marginalised and ‘inclusion’ health and care. Further points about engagement and co-production are threaded throughout the top tips.  

CQC will form judgements of current performance but also of the direction of travel – are things getting better, staying the same or deteriorating? Are your improvement priorities set accordingly?

The key to self-assessment is to foster an internal culture that is robust, balanced and show critical awareness of your strengths and areas for development.  Demonstrate confidence in your strengths and progress with clear evidence and acknowledge the things that require improvement or transformation and have a realistic plan for doing this. Encourage ASC colleagues to avoid sweeping statements and assertions that can’t be evidenced, as any inconsistencies may become an unexpected line of enquiry for CQC. If this happens, present evidence quickly to reassure inspectors.

Create an evidence portfolio to support assessment and assurance, but be succinct and focused in your written self-assessment questionnaire.

• Ensure ASC leadership and the council knows the strengths and any shortfalls or risks to its delivery of ASC.
• Be aware that small failings in something serious will overshadow a lot of good practice.
• Understand and assess the implications of the challenges you know you are carrying; for example, in an assessment, serious failings in safeguarding or poor contract and quality management of providers who have poor CQC ratings are likely to trump resource challenges or how well you deal with inter-agency disputes around care. 
• Ensure top level business plans and priorities for 2022/23 and the years ahead show awareness of shortfalls or risks in performance and have a credible corporate or ASC risk management/mitigation plan for addressing the issues.

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