We're changing the way we regulate, inspect and rate dental, ambulance and independent acute healthcare services. Please tell us what you think of our plans.
About this consultation
Earlier this year, we asked for your views on our plans to change the way we regulate, inspect and rate adult social care services, NHS acute hospitals, community health, specialist mental health services and NHS GP and out-of-hours services. We published our response to this consultation and final guidance documents for these services in September and October 2014.
We now want to find out what you think about how we're planning to change the way we regulate services that were not part of the first consultation.
This includes things like:
- what we look at on an inspection
- how we judge what 'good' care looks like
- how we will, or won’t, rate services to help you judge and choose care if you want to
- how we use information to help us decide when and where we inspect.
Our detailed plans are set out in three consultation documents for:
- NHS and independent ambulances
- Primary care dental services
- Independent acute healthcare
We developed the changes outlined in these documents over the past year together with the public, providers, our staff and organisations with an interest in our work. The changes were originally signalled in our three-year strategy in April 2013 and we developed our thinking by setting out some initial proposals in a series of fresh start documents. We've also been testing our new style inspections in ambulance and independent acute healthcare services. We will be testing them in dental services from December 2014. Our final plans, developed using the feedback from this consultation, will be published in early 2015 and the changes will come into effect in April 2015.
The main changes are:
introducing new ways to inspect services, with Chief Inspectors and more specialist teams that include members of the public
using a new system of intelligent monitoring to help us decide when, where and what to inspect.
listening to people's experiences of care and using the best information across our monitoring system.
judgements based around the five key questions we ask of all services:
- Are they safe?
- Are they effective?
- Are they caring?
- Are they responsive to people's needs?
- Are they well-led?
Ratings based around the five key questions for ambulance and independent acute healthcare services.
Our plans currently propose that we won’t rate primary care dental services but we are interested in your thoughts about rating them in the future.
Royal College of Physicians of Edinburgh Care Quality Commission consultation on Our approach to regulating the Independent healthcare acute sector
The Royal College of Physicians of Edinburgh (the College) is pleased to respond to the Care Quality Commission consultation on Our approach to regulating the Independent healthcare acute sector.
The College has the following comments on specific consultation questions:
1. Do you agree that our approach to separating independent healthcare providers into three groups as described above is meaningful and appropriate? If you are an independent healthcare provider, can you readily recognise which of the three groups you fit into? If not, do you have any suggestions for how the three groups could be otherwise structured or better defined?
Yes. Due to the diversity of private services, there is a need to try to categorise the services. Therefore, the suggestion of three divisions appears to be a satisfactory attempt to address this complex area.
2. Do you agree with the approach we are proposing for regulating independent acute hospitals? Do you have any suggestions for other things we could take into account?
Yes. There is a need to regulate independent acute hospitals. However, there are two major problems which need to be overcome to ensure that inspections and grading of these units are meaningful. The first is to ensure that accurate data is collected. The College would appreciate clarification on what data is already collected in independent acute hospitals. Should more data be collected, and is there any way that it can be checked for accuracy? If a patient with complications from surgery conducted in a private hospital gets admitted subsequently to the local NHS Trust then this may not be recorded. Additionally, private hospitals may state that they do not employ consultants; rather the consultants are private contractors who provide services to that hospital. The CQC would need to ask each consultant to keep data on private patients seen and outcomes in this scenario. This would then have to be collated to give an accurate picture.
The paper describes another problem, which is not answered. The CQC will require feedback from the local population about local services. However, a private hospital’s population may be more diverse and in some cases spread over a region. Achieving meaningful patient/user feedback may become more difficult.
3. Do you agree with the approach we are proposing for regulating single specialty services? Do you have any suggestions for other things we could take into account?
In regulating single specialty services listed in the paper, some specialty services may be easier to regulate than others - haemodialysis services will be linked to renal units based in NHS Trusts, thereby allowing accurate data on outcomes, complications and feedback being achieved. In contrast, we have seen a growth in private diagnostic imaging services being set up. This growth has come about from increasing use of private diagnostic imaging being conducted within NHS Trusts. To ensure that these private radiology services are providing a safe, effective and well led service will entail input from their NHS users and potential follow up unannounced visits.
4. Do you agree with the approach we are proposing for regulating non-hospital acute services? Do you have any suggestions for other things we could take into account?
Do you agree that we should continue to engage with non-hospital acute providers before deciding on ratings? What sort of guidance would be useful for this sector in the meantime?
The College agrees that, when trying to rate non-hospital acute services, a different inspection system will be required. However, some form of rating system is required to help the consumer assess the suitability of that service before paying for that service. The rating system requires to be fair, consistent and replicable. To achieve that, the desired rating system may require a longer lead time than that proposed in the paper.
5. Do you feel confident that the changes we propose to the acute provider handbook will help our inspectors to assure the public on how safe, effective, caring, responsive and well-led independent acute hospital and single specialty providers are? If not, what is missing?
Yes, the College agrees that the changes being proposed to the acute provider handbook will help the inspection process. Currently NHS Trusts are subject to considerable media interest due to public awareness of patient safety concerns, etc, and therefore it is vital that private units undergo rigorous assessment similar to NHS Trusts to ensure that a safe service is being provided. The process across both NHS and private units needs to be transparent. The independent domain may be more challenging to assess as consultants working in the independent acute sector will normally be independent practitioners and not involved in day to day management, or providing a leadership role. It would be useful to convene a Quality and Leadership summit addressing these issues in the independent sector.
6. Do you have any suggestions for how we could develop our approach to special measures in the independent acute sector?
It is important that there is equivalence across NHS and independent providers in the approach taken to special measures.
The College would appreciate clarification on the enforcement policy mentioned in the paper and it is important that any definition of NHS dependency on private services, which would lead to different thresholds for closure, is made explicitly clear. The effects of special measures on adjacent providers should also be considered.
7. Do you have any suggestions for how we should or should not develop our approach to corporate provider assessment in the independent acute sector?
The College feels that a corporate provider should be assessed on two levels. The first is assessment of what is being provided at a local site and local managers being held responsible for what is happening within that unit. The second is the need for a provider to have corporate responsibility for what is taking place at a local level and analysis of how corporate policies may positively or negatively impact on patient care or safety.
8. As part of this consultation we have published a Regulatory impact assessment. We would also like your comments on this.
The impact of the new regulations will encourage the private sector to raise standards, as they will be very conscious that a poor rating will negatively affect their business. There will be a need for the CQC to enforce these regulations and stand up to potential legal action by private providers, who may fear the loss of revenue that a negative assessment could potentially have on their business.