Policy responses and statements
- Name of organisation:
- Care Quality Commission
- Name of policy document:
- Our Strategy for 2010-2015
- Deadline for response:
- 24 December 2009
Background: The Care Quality Commission
(CQC) is the new regulator of the quality of health and adult social
care in England. Its task is to make sure that essential standards
are met wherever health and social care is provided, and that people
experience a better quality of care.
This publication outlines the CQC's role as regulator and how it plans
to carry out its responsibilities over the next five years.
As the first regulator in England to work across health and social
care, CQC has a unique opportunity to take a new approach. Not only
will it assess individual services throughout the country, but it is
also able to look at how well the two sectors work together to bring
people better integrated care.
The CQC's plans are not fixed, and it wants to hear comments and suggestions
on how best to use its powers and resources to achieve the best possible
care for people.
The questions it is asking in this plan are:
- Has the CQC set the right priorities to improve the quality
and safety of care?
- Is the CQC planning to go about its work in the right way?
- Is the CQC clear about its role in improving the quality of
care for people in the wider system?
- How can CQC's regulation:
Strengthen the voice of people in CQC's assessments of the quality
of care?
Improve services and organisations where performance is poor?
Contribute to better integrated and joined-up care?
- How can CQC streamline regulation most effectively?
- How can respondents support the achievement of CQC's plans?
The CQC looks forward to receiving feedback. It plans to publish its
final strategic plan in early 2010.
COMMENTS ON
CARE QUALITY COMMISSION
STRATEGY 2010-2015
The College welcomes the opportunity to respond to this first strategic document
from the Care Quality Commission. This response reflects particularly the views
and experiences of our Fellows and Members working in England.
General Comments
The strategy helpfully lays out the regulatory framework within which CQC
will operate and acknowledges the need to work in partnership with other regulators,
including Monitor and the Audit Commission. It is less clear how the new Quality
Accounts will be used by CQC or who bears the ultimate responsibility for collating
the evidence gathered by all the regulators and assessing the overall quality
of care and service delivered.
The College notes the difficult financial climate and the recognition by CQC
of the need to prioritise their activities carefully. The regulatory scope
is enormous and the strategy document would benefit from a clearer indication
of how the CQC propose to allocate their funds across the 5 strategic priority
areas.
Managing patient and staff expectations as demand grows without matching increases
in funding will be a challenge for the NHS and the CQC strategy should acknowledge
this challenge.
The following comments address the consultation questions set out in the foreword
to the document
1. Have we set the right priorities to improve the quality and safety
of care?
The College agrees with the priority given to the patients’ perspectives
but is concerned that, taken in isolation, this could distort judgements about
quality of care. The College recommends greater balance is introduced into
the strategy with references to objective (outcome and process) measures where
appropriate and advises that this will require scrutiny of audit capacity and
clinical information systems.
2. Are we planning to go about our work in the right way?
The strategy is a high level document and it is difficult to comment on the
approach in any detail at this stage, although the 5 priority outcomes listed
in chapter 3 are welcome. There is a conflict between the priority outcome
3 (focusing on the weakest 10%) and outcome 4 ( promoting high
quality care) and the College would encourage CQC to use it’s regulatory
power to support continuous quality improvement in addition to identifying
and correcting unacceptable care.
The College appreciates that the Regulator will, on occasions, have difficult
news for the clinical community but recommends that all assessments are based
on transparent evidence and data to secure the confidence of doctors.
3. Are we clear about our role in improving the quality of care for
people in the wider system.
The College understand the importance of involving local people but if services
are to be responsive to local needs and priorities there will be an inevitable
conflict with national standards and perhaps inequalities for some patient
groups. It is unclear how CQC will cope with this conundrum, allowing some
local flexibility and yet regulating against national standards.
The proposed annual review of the quality of commissioning is particularly
welcome as it will bring a quality focus to the monitoring role of the SHAs.
The CQC should retain responsibility for ensuring the SHAs/Monitor follow up
action plans with their providers in response to CQC assessments.
4. How can our regulation:
- Strengthen the voice of the people in our assessments of the quality
of care?
By ensuring patient representatives or their advocates have training and time
to enable them to participate fully in the assessments
- Improve services and organisations where performance is poor?
By ensuring that assessment and action planning are constructive rather than
punitive processes, ensuring resources match required improvements and by taking
a more demanding stance only if progress is unacceptably slow.
By placing greater emphasis on identifying and disseminating success nationally
in addition to focusing on the weaker providers of care.
By ensuring the NHS continues to support the training of the next generation
of healthcare professionals. There is very limited reference to the importance
of staff development and yet over 80% of the social care and 70% of the health
budgets cover salaries and related costs. The College recommends that greater
emphasis is given within priorities to clinical staff development across all
disciplines to deliver sustainability into the future.
- Contribute to better integrated and joined up care?
Physicians understand only too well the challenges of achieving integrated
care and the difficulties caused for patients and clinical teams by organisational
boundaries and poorly coordinated priorities. Time delays in accessing appropriate
packages of care contribute significantly to patient outcomes and satisfaction
and physicians will, in part, measure the success of CQC in terms of their
impact on this long standing problem.
5. How can we streamline regulation most effectively?
The potential for duplication and inefficient regulation is high and it is
critical that all organisations with a regulatory remit collaborate closely
over their information needs, required presentation styles and assessment timetables.
There must be clear added value resulting from the assessment activities of
CQC if it is to retain the confidence of patients and healthcare professionals,
particularly at a time when funding for frontline services may be questioned.
The College is concerned that financial and other pressures facing Foundation
Trusts could generate conflict between Monitor and CQC and it would be important
to avoid this problem.
There should be regular review of the overall regulatory system to identify
opportunities to share and reduce the complexity in terms of the numbers of
organisations with overlapping remits.
Light touch regulation should be in place for providers with clearly established
information systems and evidence of responsive care that meets the required
standards.
There is a clear need for more effective and accurate clinical information
systems that will generate the required information for all users and regulators.
6. How can you support the achievement of our plans?
The combined expertise of the Medical Royal Colleges through the UK Academy
offers a reliable and independent source of clinical expertise to support the
work of the CQC at many levels, whether for strategic planning, standard setting
or the interpretation of assessment data and the formulation of action plans.
This may be particularly important in the evaluation of new technologies and
their impact on health inequalities, where competing influences from healthcare
industries could drive patient demand inappropriately.
Copies of this response are available from:
Lesley Lockhart,
Royal College of Physicians of Edinburgh,
9 Queen Street,
Edinburgh,
EH2 1JQ.
Tel: 0131 225 7324 ext 608
Fax: 0131 220 3939
[23 December 2009]
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