Soon a new type of inspector will call

You and the Care Quality Commission in 2021 and beyond – what does its new strategy mean for independent healthcare providers? David Hare reports.

Healthcare is an ever-evolving industry and, indeed, the past year alone has led to significant change for all parts of the health system and those who work in it. 

As healthcare delivery advances, so must regulation, with last month seeing the publication of the Care Quality Commission’s (CQC’s) new strategy for 2021 and beyond. 

The CQC has promised that it will result in its regulation being ‘more relevant to the way care is now delivered, more flexible to manage risk and uncertainty, and will enable us to respond in a quicker and more proportionate way as the health and care environment continues to evolve’. 

But what will it mean in practice for independent healthcare and those who work in it?

At the heart of its new strategy is the desire to become a more ‘dynamic regulator’ which can provide an up-to-date and accurate picture of quality in the health system and, importantly, make it easier for services as well as patients to exchange relevant information with them. 

From the private sector’s perspective, this is a welcome ambition. 

Outdated information

For some time, we at the Indep­endent Healthcare Providers Net­work (IHPN) have raised concerns that CQC ratings can be based on inspections undertaken several years ago, with providers holding a ‘requires improvement’ rating based on outdated information and little prospect of an inspection to improve the rating. 

This not only impacts on providers but also the ability of both patients and commissioners to make meaningful choices based on the best possible information. 

And likewise, many independent providers who have multiple sites across the country are subject to often repetitive requests for information and data.

They could certainly benefit from a much more flexible regime which acknowledges the differences between the NHS and independent sector and works to streamline processes without compromising on quality.  

Having up-to-date access to accurate data is, of course, key to the CQC becoming a more ‘responsive and relevant’ regulator.

Complete picture

But the devil will be in the detail and IHPN will closely engage with the CQC about its agenda. 

While it is positive that the CQC will use data from the Private Healthcare Information Network (PHIN) and the NHS Digital’s Acute Data Alignment Programme (ADAPt), this will not necessarily provide a complete picture. The CQC will also need to get data directly from providers to be able to make an accurate assessment. 

Greater clarity will be needed about how this additional data and intelligence will be used to support a model of continual assessment for the full range of independent providers. 

Linked to this, the CQC’s strategy also focuses on what it can do to help drive and accelerate improvements in safety and quality across the healthcare system. 

We welcome its proposals to provide more clarity on standards of care, increase engagement around improvement and to increase benchmarking data. 

Hopefully, this will lead to:

 More opportunities to share best practice about safety and quality;

 An ability for providers to ask for advice and guidance without fearing this will affect their rating;

 A CQC framework to support providers with a ‘requires improvement’ rating. 

In line with the health services’ wider move towards integrated care systems and delivering more joined-up care, the CQC is keen to mirror this approach and work towards assessing healthcare on a systems level. 

Definition of safety

System-wide collaboration and a shared definition of safety is vital to sustaining and building safety across the healthcare landscape. With an ageing population and growing numbers of people with multiple chronic conditions accessing a range of services, this is undoubtedly the right way to go. 

But this will undoubtedly be the most challenging to achieve. 

Key to getting ‘system-wide’ assessment right will be ensuring that the unique attributes of the independent sector, and the ways it participates in the UK’s healthcare system, are recognised and accounted for. 

For example, people’s interactions with the independent sector can differ from those with the NHS. A patient may only interact with private healthcare for one test or procedure as part of their pathway. 

Awareness of these differences and a move away from a one-size-fits-all approach to assessing providers with a systems-level view will be vital.

We would welcome the opportunity for the sector to contribute to the CQC’s forthcoming pilot studies to test out this new ‘system-wide’ assessment.

Other CQC ambitions include better engagement with patients and communities and ensuring everyone is empowered to speak up about their healthcare experiences.

Providing feedback  

It is a welcome ambition, but it is important the different feedback people may have for private sector and NHS providers is recognised. 

While many independent sector providers deliver NHS-funded care, they also serve private insurance and self-pay patients from the UK and overseas who may provide feedback differently than they would to an NHS trust or social care service. 

There is much to digest in the CQC’s new strategy, but the independent sector and its workforce should be prepared for an evolutionary rather than revolutionary approach to regulation. 

And with the Department of Health and Social Care working hard on its response to the Paterson inquiry, it is likely that there will be many more recommendations for the CQC and how it regulates all healthcare providers. 

The coming months and years will therefore prove an interesting time for healthcare regulation.

Providers and practitioners should be reassured that the IHPN will be working closely with the CQC and other regulators to effectively represent the sector and ensure providers in the sector can continue to deliver ever better care for their patients.

David Hare is the chief executive of the Independent Healthcare Providers Network