Important update for all Registered Providers, Registered Managers and Nominated Individuals. From January 2019 the CQC is introducing a new element to the reporting process:-

“From 28th January, we will be rolling out improvements to ‘how we report’. This follows work to coproduce and pilot these with providers and inspectors (find full details on this in our next provider newsletter). Reports will be clearer to the reader and a small but important improvement we’re introducing means that, after the registered manager receives the draft report, the inspector will call them to talk through the evidence. In our piloting of this, we’ve found it has helped providers to better understand how we arrived at our judgments and helped clarify issues or concerns or celebrate Outstanding care. As a result, some challenges that might previously have been made have been avoided which has allowed us to publish some reports more quickly – a good thing for providers, CQC and the public.

It’s this type of change that you’ll be seeing from CQC this year – changes that come from us listening to our staff, providers and the public about what works and where we can refine our approach to help us work better together. We remain committed to working in coproduction to make these changes not just because it’s the right thing to do, but because it helps us get these improvements right. We may not always be required to carry out a formal consultation by law, but – in the spirit of the Quality matters commitment we made with the sector in 2017 – we will always engage with our stakeholders to ensure we hear first-hand from you what the impact of any change might be”

Debbie Westhead, Interim Chief Inspector of Adult Social Care. This is the link to the full article.

ProRisk Comment

The inherent risk for Registered Providers / Mangers with this new development is the subtle pressure that may be applied to get you to agree with the CQC findings BEFORE you have had time to digest the draft report. More significantly, before you have had time to do your factual accuracy check.

If there is any implied agreement with the CQC findings during this post draft report telephone call then that could be noted and recorded by the CQC. This could unfortunately compromise any factual challenge to the daft report that you wish to make, subsequently.

So it is crucial that you maintain a neutral stance during the telephone call. Listen, ask questions, seek clarification, take notes but make no response. It is a classic ‘no comment’ on the part of the Provider / Manager until you have had time to digest the draft report. Do not be pulled in to agreeing with or consenting to the findings.

On the other hand it is, as the article implies above, an opportunity for challenges to be headed off. There may be obvious facts that you can correct during the call. It is a fine line and one that the Register Manager will need to be alert to.

ProRisk Care will be adding some guidance notes on how to prepare for the telephone call as soon as it has some feedback from clients’ actual experiences.

Caroline Lower
ProRisk Care Consultant

11.3.19