Published: 12 November 2021
Ted Baker, our Chief Inspector of Hospitals, has written to NHS Providers and the NHS Confederation to clarify our regulatory approach during winter.
"As we head into winter, I wanted to write to you to clarify CQC’s regulatory approach during this period. While our priority will always be on ensuring that people are receiving safe care, we are only too aware of the extremely challenging context in which providers are operating and the resulting pressure on staff.
Our inspection approach remains risk based, with the key criteria for inspection being the need to investigate whether people are or could be at risk of harm. Since the onset of the pandemic, the majority of our inspections have been triggered by concerns raised with us by staff and people who use services, on which we have a duty to act. With no planned return to routine frequency-based inspections for the time being, it remains more important than ever that staff continue to raise concerns, and feel free to do so. Our inspections can make sure the voices of staff and people are heard and escalate their concerns, some of which cannot be resolved at provider level but demand a national response.
We continue to work closely with other parts of the system, primarily NHS England at regional and national level, and many concerns are being resolved and risks addressed without the need for us to inspect services. Where inspections are necessary, we use the evidence we gather to escalate issues on behalf of providers and demand a national response where concerns cannot be resolved at local level. We have had feedback from some providers that our inspections have been a valuable catalyst for accessing additional support.
We have consistently highlighted on the relationship between different care settings and across local systems as being crucial to the provision of good, safe care. Over the coming winter, we will focus on activity that increases capacity across the health and care system as a whole – for example supporting improvement in individual adult social care in order to increase the number of providers delivering good care, and providing assurance around ‘designated’ social care settings that can safely care for people with COVID-19, enabling them to leave hospital faster. As you know, we used our State of Care report to call for an extension to the Discharge to Assess fund, a resource which has helped the NHS to treat more patients while strengthening relationships with social care - and we continue to amplify messaging from this report about the need for new models of care, with services designed around local need so that people get the right treatment in the right place at the right time, delivered by a workforce who are valued and supported.
As part of our move towards assessing care as part of a system, we are planning a more co-ordinated approach to inspecting urgent and emergency care pathways this winter, which could involve inspecting more than one provider, location or core service within a system to better understand overall patient experience. These risk-based inspections will look at how different part of the system – for example, a 111 service, an ambulance service and an acute provider, as well as primary care, community and social care providers - are working together in order to understand what improvements could be made to benefit people using services and staff delivering care. Providers we have spoken to have welcomed this approach, informed by the recognition that services do not operate in isolation, as having the potential to deliver genuine improvement across systems. In line with our continuing work to ensure that the impact of inspection activity on staff time is minimised, this will not involve any additional information or data requests to providers beyond the essential requirements of our focussed inspections.
Finally, I would like to encourage providers who are considering innovative approaches to delivering safe care in these difficult circumstances to talk to us, rather than assuming that we would oppose necessary actions to sustain services under the extraordinary conditions they face.
Thank you as ever for the insight and genuinely constructive challenge you continue to provide. I am happy for this correspondence to be shared with your members."