We want to tackle inequality to make sure everyone has good quality care, as well as equal access, experience and outcomes from health and social care services.
This is in line with our strategy and our core purpose.
We also have a duty to publish equality objectives to meet Equality Act 2010 regulations.
The coronavirus (COVID-19) pandemic has magnified and exposed longstanding inequalities in health and social care. Everyone in health and social care needs to understand their causes and take action to address them – including leaders who influence what happens locally. This is part of our strategy.
We do not set the priorities for reducing inequalities and will work closely with other bodies who have these roles to align our work. But as an independent regulator, we will take appropriate regulatory action or speak up where care isn't good enough for any groups of people.
Our strategy gives us new opportunities to help reduce inequalities. These five equality objectives are priorities and aim to help to deliver equality for:
- people who use health and social care services
- people working in health and social care
- health and care providers that we regulate
- our own workforce
These equality objectives cover 4 years, because that is in line with the Equality Act 2010 regulations.
We used our strategy and its equality impact assessment to set these objectives, and then developed them using:
- people's feedback when developing the strategy and from the formal strategy consultation
- workshops at our CQC staff conference, attended by over 100 colleagues and further workshops with colleagues to develop the content of each objective
- a survey of 1,000 members of the public
- conversations with groups representing different stakeholders
We have also reviewed progress on our previous equality objectives for 2019-21.
- These objectives focused on specific topics and on embedding equality into our regulatory methods and into developing learning for staff. As a result, we now have good processes and approaches for ensuring we look at equality in these activities.
- Our regulatory equality objectives from 2021 focus on aspects of our regulatory work such as using evidence and joint working. These are important to deliver our strategy.
- Our objective on equality for our workforce builds on our previous objective.
This work has been overseen by our Equality and Human Rights Co-ordination group and was agreed by our board on 21 July 2021.
People most likely to have difficulty in accessing care
These are groups of people who face barriers in getting the care they need, for example:
- homeless people, Gypsies and travellers and migrants to the UK
- people who may be receiving care but cannot access the most appropriate care for their needs, such as people with a learning disability and autistic people who are inappropriately placed in hospitals for long periods
People most likely to have a poorer experience of care
To reduce inequalities, we need to focus on the quality of care for those most likely to have a poorer experience. This does not mean that we are looking for poor care – it means we are looking for good care for these people.
The groups of people who are most likely to have poorer access, experience or outcomes will vary between different types of services, people's individual circumstances, and between places
We will develop a definition of the main groups. Over time, we will also develop our understanding of inequalities, as we have more evidence. The first two equality objectives set out activities that relate to some groups of people who are more likely to have difficulty accessing the right care or to have a poorer experience of care:
- people from Black and minority ethnic groups/communities, especially if they are using mental health services or maternity services
- people with a learning disability and autistic people
- people with dementia
- people with serious mental illness, people detained under the Mental Health Act and people who may not have mental capacity to make some important decisions, such as decisions about their care and treatment or where they live.
- people who need accessible communication including Deaf people and people who do not speak English
- Lesbian, gay, bisexual and transgender people
The success indicators for each equality objective are designed to align with our strategy.
- Although we don't have baseline figures yet, we will obtain them as we implement different aspects of the strategy. Because of this, the exact wording of indicators may change.
- We may review our progress before 2025 and revise the actions needed to meet our objectives.
- We will report on progress in meeting our equality objectives in our annual reports.
Equality objective 1: Amplifying the voices of people most likely to have a poorer experience of care or have difficulty accessing care
We will improve how we gather and act on the experiences of people most likely to have a poorer experience of care and those least likely to be able to access the care they need. We will expect health and care providers to actively seek out, listen and respond to people who are most likely to have difficulty accessing their care or a poorer experience or outcomes from care.
Our plans:
1. We will develop how we act on people's experiences so we can tackle inequality in care
This includes improving equality monitoring when people share information with us. It also includes looking at how we use people's experiences of discrimination, inequality and human rights and Mental Health Act concerns, so we are clear what action an individual experience should trigger. This will help us respond more systematically to individual concerns.
2. We will increase the amount of digital feedback from people most likely to have a poorer experience of care or have difficulty accessing care and their representatives
We will do this through our online ‘Give feedback on care' service. We will also run campaigns to reach specific groups of people, for example younger lesbian, gay, bisexual or trans people, and forge more national partnerships with organisations that represent people more likely to have a poor experience of care or have difficulty in accessing care.
3. We will increase the amount of non-digital feedback from people likely to have a poorer experience of care
This means focusing on people who don't have access to digital ways of communicating or who can't or don't want to use it. We will make better use of information about inequalities gathered by others, for example local Healthwatch organisations. We will set up a video relay service to enable Deaf people to give us feedback using British Sign language and improve our ability to hear from people who speak languages other than English. We will develop tools to communicate in person with people who have a learning disability, autistic people and people with dementia. We will also look at how our local teams can prioritise local outreach in the year, to increase our evidence about equality in access, experience and outcomes.
4. We will encourage providers and local systems to actively seek out, listen and respond to people who are most likely to have difficulty accessing their care or a poorer experience or outcomes from care
We will include this in our assessment frameworks and provide local teams with tools to help them to assess how well providers and local systems do this.
Impact for people using services, their families and friends
- “I will be able to tell CQC about my care or the care of someone in my family or someone I am advocating for in a way that I find easy.”
- “If I have experienced discrimination or inequality, CQC will take the right action to improve the service.”
- “I will be involved in decisions about my care. CQC has encouraged the services that I use to seek my views about my care, my rights and my safety.”
Impact for service providers and local systems
- “CQC has a focus on the experiences of everyone who needs to access or use our services. CQC checks that we are actively seeking, listening and responding to the views of people most likely to have a poorer experience of care or those who face more barriers to accessing services.”
- “Our services are better because they meet the needs of everyone and support them to live their best life.”
Outcomes if we are successful
We are confident that we understand everyone's needs and experiences and this drives our regulation.
- We have a better understanding of the people who are less likely to engage with us and will use this to plan future engagement activity.
- We are able to gather and act on the views of a more diverse range of people, either directly or through effective local partnerships with voluntary organisations, especially those representing people facing inequalities.
- We act on the experience of individual people as key evidence, so we are able to respond well to inequality, including the human rights risks associated with inequality and the unequal experiences of people who are detained or deprived of their liberty
- People more likely to have a poorer experience of care will increasingly feel they're able to be partners in their own care, and that their human rights and safety are prioritised.
- Local systems will improve access, experience and outcomes by listening and responding to people most likely to have poor experiences and outcomes from care or difficulty accessing care.
How we will measure whether we have been successful
We will look at setting appropriate targets for the following indicators against baselines:
- The volume of feedback about people's experiences of care that we can act on from our stakeholders and people themselves, including those more likely to have a poorer experience of care
- The number of people, including those more likely to have a poorer experience of care, and the organisations who represent them, who say it is easy to share feedback on care with us.
- The percentage of our assessment and review outputs about services that include the views and experiences of people, including those more likely to have a poorer experience of care or have difficulty accessing care
- The percentage of operational colleagues who say we give appropriate weight within regulatory activities, decisions, and judgements, to people's experiences of care.
- The amount of local engagement with groups of people most likely to experience inequalities and the percentage of staff who say that this engagement has informed our regulatory work.
Equality objective 2: Using data to understand and respond to equality risks
We will improve how we collect, analyse and use data and information so that we can respond better to equality risks at the level of an individual service, a corporate provider of care, and a local area. We will use our independent voice to publish what we find at a national level. This work covers inequalities in access, experiences and outcomes, including human rights risks that affect specific groups of people. We will also build on our existing work to consider data and information to identify risks to workforce equality in organisations that we regulate and to ensure that we are regulating providers fairly and equally.
Our plans:
1. Through taking an “equalities by design approach” we will identify and prioritise inequalities and risks to equality and human rights as we develop different intelligence and data projects
This includes aligning our work on national priorities, for example NHS health inequalities priorities.
2. Where needed, we will then develop priority areas for our own data collection around equality risks
Current work in includes equality monitoring in statutory notifications, through our Mental Health Act activities, collecting information on the use of restraint, segregation and seclusion in adult social care services, and people's involvement in advance decisions about resuscitation (DNACPR) in all health and social care services.
3. We will also develop priority areas where we can use better analysis from existing data, ensuring that the equality risks this identifies trigger the right regulatory response
This will build on existing work underway, for example:
- human rights risks in adult social care and mental health services, as these are also equality risks, building on our intelligence development work around ‘closed cultures', and improvements in our Mental Health Act programmes
- access, experiences and outcomes for people from Black and minority ethnic groups/communities using mental health services in line with our commitment to Advancing Mental Health Equality and Mental Health Act Reform
- developing intelligence on the experience and outcomes for Black women using hospital maternity services, building on our engagement with the national work on reducing poorer outcomes for Black women and their babies
- developing intelligence that shows how GP practices reduce health inequalities for people with a learning disability, including access to screening, vaccination, accessible information and reducing over-medication of psychotropic drugs
- Improving how our local teams use our data analysis on workforce equality, aligning with national programmes such as the Workforce Race Equality Standard and Workforce Disability Equality Standard in NHS services
- improving how our local teams use equality information that we collect through the provider information return for adult social care services.
4. We will take an “equalities by design” approach to data development at a local area level and in our national reporting
Topics will depend on our future priorities for area-based work. This will build on our learning from Provider Collaboration Reviews, about people with a learning disability, older people and children and young people needing mental health support, which included Mental Health Act pathway information. Within each of these reviews we considered health inequalities with a focus on inequalities for people from Black and minority ethnic groups/communities. Wherever possible, we will develop the priorities at a provider and a local area level so we can also report at a national level (see equality objective 4).
We will develop how we hear from frontline staff working in health and social care about workforce equality issues
We aim to collect experiences throughout the year, rather than just during an inspection visit.
We will use data and feedback on experiences to ensure fairness and equality in our decision making
We will look at the relationship between our quality ratings and enforcement action and the ethnicity of GPs who lead practices, to identify whether there are differences, establish causes and take necessary action.
We will encourage other organisations that we work with to improve how they collect data about inequalities and equality risks
We use data from many different sources.
Impact for people using services, their family and friends
- “I am likely to have access to local health and social care services that meet my needs and help me to live my best life. CQC has helped by using data to encourage local areas to consider inequalities in people's access and outcomes.”
- “The services I use will meet my needs and support me to lead my best life. This is because CQC knows more about whether who everyone uses a service has equally good care and has taken the right action to respond to this information.”
- “If I have shared equality information about myself with CQC or with others in health and social care, CQC will use it when regulating services. For example, if I give information about my ethnicity, disability or sexual orientation, through equality monitoring.”
Impact for people working in health and social care services
- “The information that I give to CQC or another body about my equality characteristics or any inequality in my employment is more likely to improve my experience at work. This is because CQC will use this information well to assess the leadership and culture of the service where I work.”
- “If I am leading a regulated service, I can be confident that CQC regulates fairly and without bias, because it will analyse outcomes from regulation by equality characteristics. CQC will make sure that that it regulates fairly and will encourage improvement in local and national systems that might be contributing to differences in regulatory outcomes.”
Impact for service providers and local systems
- “CQC uses data well to understand the quality of care for everyone using our service and to take the right action at the right time.”
- “CQC shares data on equality with us, so we can improve.”
Outcomes if we are successful
We are confident that we use data well to understand the quality of care for everyone using a service and equality for staff working in services, and that we take the right action on equality based on the data that we hold.
- We use best practice when gathering data on equality and we influence services and providers to do the same.
- We analyse data on inequalities and equality and human rights risks and use it to take fair and proportionate action in our regulation of services and providers.
- We share more data on equality in access, experience and outcomes, human rights risks and workforce equality at a service, provider, local area and national level.
- We understand whether we are acting fairly and without bias in our regulatory work and take action to improve if necessary.
How we will measure whether we have been successful
We will look at setting appropriate targets for the following indicators against baselines:
- The number of data items relating to equality risks in our risk models for different providers in line with identified priorities, including human rights risks where they affect equality groups differently.
- Data on equality risks that triggers appropriate regulatory action, assessed through quality assurance.
- The use of data and information on equality risks in the reports we publish about our assessments.
- The number of services, local stakeholders and our operational colleagues who say we maintain an up-to-date picture of quality of services, and in local systems, through a range of information.
Equality objective 3: Working with others to improve equality of access, experience and outcomes
We will review who we work with and improve how we work with them so that we can push for equality of access, experience and outcomes. This includes working with others at a local system level. We can respond more flexibly and adapt to equality issues through better joint working with other regulators and commissioners. This include human rights issues that affect groups of people.
Our plans:
1. We will consider how new improvement coalitions can embed the need to reduce inequalities into the support that's available to help health and social care providers and local systems to improve
2. When we build our new information systems, we will develop ways to record any qualitative data from other organisations
This includes how we can analyse this in relation to inequalities in access, experience and outcomes from care, unequal human rights and safety risks and workforce equality.
3. We will build skills and capability in our local teams so they are confident in using information about access, experience and outcomes from care and human rights risks when we work jointly with other bodies at a local level
4. When reviewing our memoranda of understanding with key organisations we will aim to strengthen them around reducing inequalities
We will also deliver the action plan for our Memorandum of Understanding with the Equality and Human Rights Commission and develop the action plan as required.
5. We will consider the learning from our escalation process developed during the COVID-19 pandemic
This process provided effective ways to escalate to other bodies any emerging equality and human rights issues that we saw through our regulatory work at both local and national levels. For example, we were able to escalate the emerging issues around failure to involve older and disabled people in do not attempt cardiopulmonary resuscitation (DNACPR) decisions.
6. We will respond to recommendations made by others relating to equality, inequalities and human rights
This will enable us to play our part in agreed national priorities for reducing inequalities in health and social care.
Impact for people using services, their family and friends
- “I am more likely to have access to the right care, at the right time, because CQC will be talking to others about inequalities in access. For example, organisations that commission health and care services.”
- “I am more likely to get good care that protects my rights where more than one organisation needs to take action to make sure this happens.”
Impact for people working in health and social care services
- “I am less likely to face discrimination at work and more likely to be supported to reach my potential. This is because CQC works with other bodies to encourage improvement in workforce equality.”
Impact for service providers and local systems
- “CQC helps us to improve our services and the local care system so that everyone receives good care because CQC is working in a joined-up way with other bodies.”
Outcomes if we are successful
We work collaboratively with other bodies to reduce inequalities in access, experience and outcomes.
- Inequalities in access, experience and outcomes are improved through better working relationships with a range of organisations at local and national levels.
- There is an effective response to local and national equality issues as they arise, through joint working between regulators.
How will we measure whether we have been successful
We will look at setting appropriate targets for the following indicators against baselines:
- The number of local stakeholders who say our work has sufficient focus on reducing inequalities in access, experiences and outcomes for people using services.
- The volume of feedback about people's experiences of care from our strategic partners and stakeholders that we can act on, (by the feedback route and whether positive or negative).
- The number of people, services and local stakeholders who say we act quickly where services fail to improve safety.
- The number of our strategic partners and other stakeholders who say they have taken action to address safety concerns following information we have shared with them from our regulatory activities.
- Our commitments with other organisations to tackle inequalities in access, experience and outcomes as measured through revised memoranda of understanding.
- Evidence of our response to recommendations made by others concerning inequalities in access, experience and outcomes.
Equality objective 4: Using our independent voice to reduce inequalities
We will use our independent voice to highlight concerns and share innovation and good practice that can help reduce inequalities at a provider, local area, and national level. When looking at health and care services in local areas, we will report on how organisations within areas are working together to reduce inequalities. We will use the learning from this work around inequalities to improve our own regulation.
Our plans:
1. In our reports on local systems, we will include how they are identifying inequalities and are acting to reduce them
This builds on our existing work to do this in our provider collaboration reviews.
2. We will publish information about the safety risks that different groups of people face and the solutions to these, particularly for those more likely to have poor outcomes from care
We will do this through working with others to develop collective understanding about safety risks for particular groups and the solutions to these.
3. In our national reports, we will highlight equality and health inequalities priorities, share good practice and innovation and make appropriate recommendations for improvement
This builds on our existing work, for example in our State of Care reports.
4. We will use our findings from our independent voice work to develop our own approach to regulating so that we help to reduce inequalities
5. We will develop our understanding of inequalities and use this to determine priority topics to highlight using our independent voice, so we can help reduce inequalities in health and social care
For example, through our work in equality objectives 1 and 2, hearing more from people likely to have a poorer experience of care and developing our data analysis
Impact for people using services, their friends and family
- “I see improvement in the care I receive because services are working to make sure that they provide good care for everyone.”
- “I find it easier to access the care I need, because local systems are working to make sure that they reduce inequalities in access to care.”
- “I am confident that I will receive safe care. I know that services are working to make sure that they are safe for everyone, including protecting human rights.”
Impact for service providers and local systems
- “We use information from CQC about inequalities in health and social care, and how to tackle them, to help us provide good care for everyone.”
- “We use information from CQC to help us improve safety for everyone, including those people at the highest risk of safety failures.”
- “People working in our services, such as staff leading on safety, are more likely to be looking at tackling unequal safety outcomes.”
- “When we work together in local systems, we have a better understanding of what needs to be done to reduce inequalities, through our engagement with CQC.”
The outcomes if we are successful
We help reduce inequalities in access, experiences and outcomes in health and social care through using our independent voice.
- Through our national reporting, we:
- identify and call out unwarranted variation and inequality
- understand why such variation in health and care exists
- explore how services embed equality, diversity and inclusion in what they do
- highlight where there is discrimination
- promote examples of where inequalities have been reduced or eliminated.
- By reporting on how local systems act on inequalities in their area, we help to ensure that everyone in that area can access the health and care services they need.
- We help foster understanding about how local health systems are influencing the wider factors that contribute to unequal health outcomes, such as poverty, poor housing, education and environmental factors.
- We help develop understanding of where safety risks are greater for specific groups of people and what solutions might improve safety. This includes reducing harm, abuse and human rights breaches. It also includes where groups of people might face safety risks when being transferred and discharged from services.
How we will measure whether we have been successful
We will look at setting appropriate targets for the following indicators against baselines:
- The number of services and local stakeholders that say our work has encouraged them to reduce inequalities in access, people feeling safe, care (and treatment) meeting people's needs, overall experience and satisfaction, and health and care outcomes.
- The number of services, local stakeholders and our operational colleagues who say our work has sufficient focus on reducing inequalities in access, experiences and outcomes for people using services.
- The amount of content in our national reports about addressing inequalities in access, experience and outcome from using care services.
- Evidence that learning from our independent voice work develops our own approaches to regulating to reduce inequalities, for example through changing our methods.
Equality objective 5: Our inclusive future: delivering on our diversity and inclusion strategy for our workforce
Our Diversity and Inclusion Strategy published in 2020 sets out our ambition to help achieve an inclusive CQC over 3 years. We have four overarching priorities:
- Inclusive leadership and accountability
- Inclusive culture
- Inclusive engagement
- Inclusive policies and practices
We will accelerate and raise our ambition of being a fair and inclusive workplace. We want to create the conditions where all our colleagues can flourish and reach their full potential and feel safe to be themselves. We want to create an environment, ultimately, where everyone makes a difference to the quality of health and social care.
Activities
1. We will meet our ambitions to have an inclusive and accountable leadership
Working with Department of Health and Social Care (DHSC) to build inclusive recruitment into Board recruitment and exploring positive action approaches. We will develop our existing programme of reverse mentoring for Executive Team and Board members. We will develop senior leaders in their cultural intelligence capability and embed inclusive leadership into long term leadership strategy. We will also build a role models campaign.
2. We will meet our ambitions to have an inclusive culture
Developing a diversity and inclusion learning toolkit and resources to help colleagues and a programme of “curious conversations” to support staff understanding and encourage people to talk to others that they would not usually have the opportunity to talk to. We will embed the use of diversity dashboards in reviews of directorates. We will work towards achieving Disability Confident Employer and Carer Confident Employer standards and improved Stonewall Workplace Index ranking.
3. We will meet our ambitions for Inclusive Engagement
Embedding diverse voices and experiences into all feedback mechanisms. We will ensure that our five staff equality networks are built into engagement processes about strategy and decision making whilst ensuring clear roles and responsibilities between equality networks, senior sponsors and organisational development.
4. We will meet our ambitions for inclusive policies and practices
Agreeing aspirational targets for percentages of colleagues from Black and ethnic staff groups/communities at grades A and above and tracking progress through diversity dashboards for each directorate. We will also use WDES data to set aspirational targets for the representation of disabled people at different grades. Reviewing our progress in increasing diversity at senior levels and implementing additional actions if required. We will develop our inclusive recruitment toolkit, including regular review of processes and review and develop our use of Independent Panel Members on recruitment panels, extending their use to shortlisting for roles and to all roles. We will ensure Equality Impact Assessments are carried out routinely for all policies and practices. We will review how we use our Talent Management Processes to create a more diverse talent pool.
Across all 4 priorities we will also deliver any other actions identified through our Workforce Race Equality Standard (WRES) and Workforce Disability Equality Standard (WDES) action plans.
Impact
Our approach and commitment to Diversity and Inclusion includes and goes beyond our legal responsibilities.
- Business benefits: We maximise the asset that diversity brings to CQC through fostering an inclusive working environment, where everyone can achieve their full potential.
- People benefits: We attract, recruit and retain more diverse teams at every level of the organisation and create an inclusive culture where our colleagues can thrive and feel valued for the experience they bring.
- Influencing benefits: We set a positive example on workforce equality, diversity and inclusion to those we regulate, to build trust and confidence with providers, the public and all our stakeholders. As a regulator, we assess provider organisations on the way they meet people's diverse needs and how they ensure equality within their teams. Therefore, it is essential that we also invest in getting this right for our own organisation.
- Legal benefits: We meet our legal responsibilities as an employer under the Equality Act 2010, including the Public Sector Equality Duty.
Outcomes
- Inclusive Leadership and accountability: Our leaders are inclusive and compassionate and role model positive behaviours. Leaders take an active role in providing solutions and strategies to progress our Diversity and Inclusion priorities and exemplify inclusive behaviours in everyday interactions
- Inclusive culture: We have a truly inclusive culture where all our people feel valued, are respected and different perspectives can thrive. We create an environment where people can be themselves at work and feel safe to share their lived experiences. We have a culture where diversity is celebrated and seen as an asset and ‘curious conversations' are encouraged.
- Inclusive engagement: All our people feel they are listened to and can contribute their ideas and experiences. We want to ensure all our feedback mechanisms include the diverse voices and opinions of all our colleagues.
- Inclusive policies and practices: We attract, recruit and retain diverse and talented people at all levels in the organisation, reflective of the communities we serve. We use our data effectively to understand the make-up of our teams and differences in experiences. All our policies and practices are open, transparent and fair.
Indicators of success
We will benchmark our progress using best practice criteria, eg WRES, WDES and Stonewall Employer Index.
We will also benchmark our progress by changes in what are colleagues tell us over time, for example through our staff survey questions.
- By March 2025 we will have increased representation of colleagues from Black and minority ethnic groups/ communities at all levels of CQC to at least match the economically active population levels and increase the proportion of colleagues from Black and minority ethnic groups/ communities progressing from application to shortlisting to offer, for all internal and external recruitment.
- By March 2022, colleagues from Black and minority ethnic groups/ communities will experience equal opportunities for career progression, promotion and development; as measured by internal recruitment outcomes, access to funded learning opportunities and survey data.
- Year-on-year reduction in the proportion of colleagues from Black and minority ethnic groups/ communities reporting that they have personally experienced discrimination of any form.
- Improve disability, ethnicity, sexual orientation, religion and belief declaration rates in Electronic Staff record to target of 95%
- Improve representation of disabled colleagues in Exec and C, D and E roles to 7.5%
- Increase likelihood of disabled applicants being appointed from shortlisting
- Reduce gap between disabled colleagues and non-disabled colleagues who say that they have experienced bullying or harassment
- Reduce gap between disabled colleagues and non-disabled colleagues who say that we provide equality in career progression and that their contributions to CQC are recognised
- Improve percentage of colleagues who have had reasonable adjustment requests met from 51% to 100% by March 2022
- Achieve Disability confident employer level 3 by March 2023
- Achieve Carer Confident employer level 1 by March 2022 and level 2 by March 2023.
- Achieve Top 50 organisations in Stonewall Workplace Index by March 2023.