In attempting to demonstrate compliance with CQC regulations providers can easily overlook several key elements. Exciting digital transformation initiatives often attract resources and energy however organisations need to ensure they are not introducing new practices into an organisation that is not built on a solid foundation. There are some key principles that will need to be in place that impact on all quality statements of the CQC criteria which we will unpack in this blog.   

What is CQC compliance based on? 

The CQC’s inspection methodology has 34 quality statements to support the five key questions:     In addition there are multiple “I statements” detailing how people should feel using a service. These all support the fundamental standards – the standards below which care must never fall.   

Why do you need to register with CQC? 

Organisations which undertake care activities in England need to assess whether those activities are covered under the Care Quality Commission’s 14 ‘regulated activities’. These are detailed in Schedule 1 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. You can learn more about if you’re at risk at straying into Regulated Activities in another of our blogs available here:   

What will the CQC be focusing on in the new inspection methodology?

The CQC regulations were designed to keep patients and staff safe. The overarching aim of a CQC inspection is to check organisations are doing this.  When rolling out the new inspection methodology the CQC issued guidance to NHS Trusts, that they will focus on Governance, Culture and Leadership in order to understand if Trust’s are Well-Led. There is a good reason for this and it’s an even better reason for organisations to reflect on these aspects. If these elements are all effective and efficient there is a good chance that the other quality statements will at least be “good.” Caveat: This may take time to permeate, and therefore there may not be immediate correlation.   

Ensuring good Governance 

Broadly, good governance should provide Top Management, and ultimately any external scrutiny, with assurance that:  
  1. The organisation is satisfying it’s legal obligations
  2. That the organisation is working towards its strategic objectives 
  3. That the organisation is aware of any risks that may affect its ability to satisfy its obligations and strategic objectives. 
  Good governance will ensure that Top Management and the CQC’s view of the organisation are aligned. Ideally the administration behind governance should be minimal with systems built to generate the information and assurance. When organisations spend more time generating reports on activity than getting on and doing the activity, they will struggle.   

Effective Leadership 

Leadership is more than Top Management. Analysis of junior and middle management can be insightful to wider organisational culture. Leaders at all levels should be trained (qualification or by experience) for the role they are undertaking. They should be able to demonstrate good knowledge of:  
  • The Organisation’s policies and procedures
  • How to manage and lead staff 
  • How to perform the functional elements of the role
  Without this, leaders will be making decisions based on their own judgement, with the level of variation on these decisions increasing with the number of leaders.  Leaders should demonstrate the visions and values of the organisation, and should uphold all the policies and procedures. When leaders choose which policies, procedures, or values they are going to abide by, so will staff. When leaders aren’t visible not only are they unable to support staff and they are unable to check and verify policies, procedures, and values are effective. Leadership is important in generating the right policies and procedures which have a far reaching impact on service provision. Senior leaders will be responsible for key policies and they will need to be able to demonstrate that they, or one of their team, have the expertise to write and police the effectiveness of policies, feeding into the organisation’s governance processes.   

Organisational Culture 

In assessing culture the CQC will be looking for organisations to be able to demonstrate they have: “…a shared vision, strategy and culture. This is based on transparency, equity, equality and human rights, diversity and inclusion, engagement, and understanding challenges and the needs of people and our communities in order to meet these. … foster a positive culture where people feel that they can speak up and that their voice will be heard.” An open and honest culture is crucial to all other quality statements, including those linked to leadership and governance. If a culture of openness and honesty is not fostered across the whole organisation pockets of closed cultures will start to exist. The CQC have specific prompts for factors pointing towards a toxic culture with specific leadership and/or management indicators.   

Summary

There is a reason organisations may not reflect on these three key areas. Culture, governance and leadership are difficult to make short term gains on. The senior leaders need to be open to appraisal of their own performance and systems they are responsible for. Changing these principles require effort and investment of resources to change. They are intertwined with any changes in one having a direct impact on the other.  Having a critical best friend, a robust internal quality assurance partner, is key to the analysis and improvement of these compliance elements. 

Other Articles​

Loading...