CQC is making changes to the Factual Accuracy Challenge Submission which is completed post inspection.  Previously this required filling in a template form with the ability to detail any items of challenge to inspector findings and to provide evidence to support the challenge.

CQC wants to improve the speed at which reports are published.  As a result it is bringing in new guidance which will apply to all providers of health and social care around the process of checking reports for their factual accuracy. It seems that fairness to Providers is being compromised as a result, however.

ProRisk Care has produced a summary of the key factors in this guidance that Providers need to be aware of.

  1. CQC Is keen to improve the speed at which reports are published post inspection.  But Providers will have to put more time and effort into the factual accuracy check when challenging the evidence in the draft report.
  2. From March 19th, CQC will provide an online template form that allows only 50 words per area of factual accuracy challenge, which is woefully inadequate. Neil Grant Solicitor and partner at Gordon’s Partnership LLP in a recent conference advised Providers to use the template form to refer to evidence documents attached, rather than trying to keep within the word count. 
  3. Providers will complete this form from March 2019 to respond to the draft inspection.  There will be a link to download the factual accuracy check form for completion.
  4. CQC will ask Providers to make it easier for them to identify changes within the report by referencing the exact location in the report that is being challenged. CQC will be requiring all challenges to reference the relevant section of the draft report, including the wording, page and paragraph number. This is good practice in any event and will help speed up the process. 
  5. CQC has now taken the decision not to disclose Inspector’s notes. At this stage, ProRisk Care is not certain what implications this will have but we will report back as soon as we have more information.
  6. Response deadlines remain the same. 10 days after the Provider receives the report.
  7. The areas of challenge are largely unchanged with the exception of the requirement that evidence is to be submitted to CQC in order to justify any factual accuracy challenges. So we advise that you organise your evidence in the same format and attach this in an Appendix to the Factual Accuracy report. (Neil Grant).

For further information on this subject, click on the link below.

Caroline Lower
ProRisk Care Consultant

12.3.19