The Home Office has appointed the Care Quality Commission (CQC) to inspect services provided to survivors of modern slavery. This guidance describes how we inspect safehouse and outreach services delivered under the Modern Slavery Victim Care Contract (MSVCC).
The Single Competent Authority at the Home Office oversees the MSVCC contract. This is currently delivered through The Salvation Army as the prime contractor and 12 subcontractors to provide specialist support to survivors of modern slavery.
We define these services as:
“The provision of residential and outreach support services across England and Wales for survivors of modern slavery, under the Home Office’s Modern Slavery Victim Care Contract (MSVCC). In England and Wales, modern slavery includes human trafficking, slavery, servitude and forced or compulsory labour.”
When we inspect, we use our Safehouse Inspection Framework and refer to the requirements in the MSVCC. We developed this based on our assessment frameworks for health care and adult social care services, and the ‘Slavery and Trafficking Survivor Care Standards’ developed by the Human Trafficking Foundation. Our framework reflects our human rights-based approach to inspection. Other stakeholders and services that provide support have also contributed. The Home Office has approved the framework and shared with service providers.
Our inspectors will use their professional judgement, supported by objective measures and evidence, to assess your service against the five key questions that we ask of all services:
- Are they safe?
- Are they effective?
- Are they caring?
- Are they responsive to people’s needs?
- Are they well-led?
Note: When inspecting safehouses, the safe key question will also directly relate to the requirements in the MSVCC contract.
Unlike most types of service that we regulate, we only have the powers to monitor and inspect for this work. Providing safehouse and outreach services is not a regulated activity so we have no enforcement powers and we cannot register these service providers. However, we will report on the findings of our inspections, which includes highlighting good practice and making recommendations for improvement where necessary. If we find a significant concern, we will escalate this to the prime contractor and the Home Office.
Our memorandum of understanding with the Home Office currently runs until June 2025, during which time we will continue to inspect these services.
Our inspections
The Home Office and CQC have agreed that all safehouse and outreach services will be inspected at least annually. Some linked services will be grouped together for inspection, based on their location or management structure. We refer to these as ‘inspection groups’.
Our inspections of safehouse and outreach services will include:
- Comprehensive inspections – we will look at all aspects of support being delivered, and report under each of our 5 key questions – is the service safe, effective, caring, responsive and well-led. We will complete comprehensive inspections of all new services, or where the Home Office asks us to do this.
- Focused inspections – we will look at one or more of the key questions and will set this out when we announce the inspection. We will complete focused inspections when following up on our previous recommendations, or where we have been asked to review specific concerns.
- Assurance inspections – we will look at the safe and well-led key questions. We will complete assurance inspections for services where we found no previous concerns and use these to find out how providers have maintained safe and well-led support for survivors.
We carry out inspections on site or remotely, depending on the issues we need to review. We will confirm this when we announce our inspection.
We may sometimes need to expand the scope of our inspection to look at additional key questions, for example if we need to report on concerns or good practice that we become aware of during the inspection.
Before inspection
Making contact with you
We require all service providers to identify a lead person and provide contact details for them. This is so we can talk to them about the inspection programme. We will contact this person before an inspection and for any other reason related to the programme or if we need information about your services. They will also need to tell us about any changes to the services you provide. You need to tell us if there are any changes to this role, for example the person’s name or contact details, so we can contact you quickly when we need to.
We will allocate an inspector to your organisation so that you know who to contact if you have any general queries about the inspection programme. This inspector will contact you to arrange regular engagement meetings. However, your designated inspector may not always carry out the inspections of your services.
Before we carry out a site visit, the lead inspector will contact you to announce the inspection, make any necessary logistical arrangements and to make sure that you are prepared for the inspection process. The lead inspector will telephone you to let you know the planned date of the inspection, and to discuss how we will carry out the inspection. We will make this call 10 working days before the planned date of our inspection.
During the initial call, the lead inspector will confirm:
- that your organisation provides the service we have told you we plan to inspect
- that the safehouse and/or outreach service is open/operating on the planned day of the inspection and that staff and survivors will be available to speak with or meet inspectors
- email addresses of staff at the service (including the service manager)
- practical arrangements for the visit such as an allocated space for the inspection team to work in, facilities available, and access to systems and documents.
The lead inspector will also:
- explain how we send the formal announcement letter to confirm our inspection
- explain what information we need you to send before the inspection and how to send it to us
- explain the inspection process
- agree a provisional inspection timetable
- discuss and agree arrangements to speak with managers and your staff
- explain about giving survivors the opportunity to provide feedback to inspectors through the survey or interviews
- ask for contact details for local services that you regularly liaise with that provide support to survivors, for example GPs, community nursing services, legal advisors, police (we may contact these services during our off-site inspection work)
- explain how we will engage with survivors and ask you about any support they will need during the inspection, such as a quiet area to talk and how to arrange interpretation needs.
If the lead inspector needs to confirm the inspection plan or answer your questions about the process, they will arrange a follow-up call with you.
Provider Information Return
Before an inspection, we will ask you to complete a Provider Information Return (PIR). This helps us to understand more about the service you provide. The PIR will ask you for information about:
- the services you provide to survivors
- external services that you liaise with
- staffing arrangements and numbers of staff
- how many survivors use your service
- how you monitor the quality of the services you provide, including the results of audits
- adverse incidents and complaints
- feedback you have collected from survivors
- policies and procedures.
This is not a full list, and we may ask for other information if we need it. You will have 5 working days to complete and respond to our request. We will tell you how and when to submit the information, and who to contact if you have any questions.
At any stage during the inspection process inspectors may need to ask you for some additional specific information to clarify queries or strengthen the evidence they have collected. We will keep track of these extra requests to avoid duplication and to make sure that we only request information that we need, which is not available elsewhere.
Engaging with survivors
We will use different ways to engage with survivors to gather their views about your service. It’s important that they have the opportunity to give feedback on their experiences.
Survivor survey
We have developed a survey for survivors to complete, available in the most common languages used by people in your services. We will give you guidance on how to distribute the questionnaire to survivors on our behalf.
When we receive responses, our inspectors will manage the information confidentially and we will use this feedback to help us to understand your service.
Speaking with survivors
During on-site inspections, our inspectors will speak with survivors who are willing to share information about their support. This will usually be an individual conversation in a private space, or with your staff present if requested. We can also speak with survivors on the telephone, or through online digital apps such as Microsoft Teams, during the inspection. This may be particularly useful for people using outreach services.
Co-operating with the inspection team
You need to co-operate with all aspects of the inspection regime, as a requirement of the MSVCC contract; Sch. 2.2, KPI 10 and 11.
Inspection
The inspection team
Each inspection will be led by a CQC Safehouses inspector. The lead inspector will be your direct point of contact throughout the inspection process. The size of your service will determine how long we spend visiting you, the number of inspectors on the team and who they are. For example, for larger services we may inspect over 2 or more days. We’ll confirm this information when we call you to announce the inspection.
Site visits
As part of the inspection, the inspection team may visit your services. They will meet with the service manager, talk with staff and review systems, documents and records for survivors. We will try to make sure that our inspection visit does not affect the delivery of services to survivors.
Introductory meeting
At the start of the visit, the inspection team will hold an introductory meeting with the service manager. This will introduce the inspection team and provide an opportunity to explain:
- the purpose and scope of the inspection
- how we will give feedback and/or escalate any concerns that we may identify
- how we will communicate our findings.
During this meeting you will have an opportunity to:
- include any staff you feel will contribute to the meeting
- tell us about the service, including the context in which it operates
- share any examples of notable or innovative practice
- tell us about any concerns or challenges for the service, and how you are addressing them.
We encourage you to be open and honest and it’s helpful if the service manager can tell the lead inspector about any concerns or other relevant information that may affect the inspection as soon as possible.
Inspection visit
During the inspection visit, the inspection team will:
- interview staff at all levels (including managers, residential support workers, outreach workers, administration staff)
- speak with survivors
- review a sample of cases
- review documentary evidence
- check accommodation (safehouses only).
We expect you to support inspectors to complete these activities. This will include:
- arranging times for interviews
- facilitating interpreting services
- ensuring that the staff and survivors who wish to speak with inspectors during the inspection are available.
- arranging for the inspection team to have access to necessary records and safehouse accommodation.
Feedback on the visit
At the end of the inspection, our inspection team will meet with the service manager, and any other members of staff who the manager has invited, to provide summary feedback. This usually includes:
- explaining our findings to date, including any issues that we need to escalate
- any plans for follow-up or additional site visits if necessary
- explaining how we make our assessments, including how we analyse any evidence after the inspection
- explaining the next steps, including the timeline for reporting
- answering your questions about the process.
We will confirm this feedback in writing shortly after our inspection.
Assessment framework
To direct the focus of our inspection, our teams will use a set of key lines of enquiry (KLOEs) that directly relate to our 5 key questions (are services safe, effective, caring, responsive and well-led?)
For safehouse and outreach service inspections, we will use our Safehouse Inspection Framework.
The framework contains tailored KLOEs relevant to the services you provide, and questions (called prompts) that inspectors will consider as part of their assessment of services.
When preparing for the inspection, our inspection teams will consider the information and data they gather, such as from the PIR and responses from the survivors survey, to decide which of the prompts they will use to help them make judgements on the KLOEs.
Mental Capacity Act
If your service provides support for adults who have (or appear to have) difficulty making informed decisions about their care, treatment or support, you may need to refer to the Mental Capacity Act 2005.
The Mental Capacity Act helps to safeguard the rights of people aged 16 and over who lack (or may lack) mental capacity to make decisions. This may be because of a lifelong learning disability or a more recent short-term or long-term impairment resulting from injury or illness. This includes decisions about whether to consent to care or treatment.
If a person’s capacity is (or is likely to be) impaired, staff must know how to ensure that decisions made on the person’s behalf are in their best interests.
After inspection
Your inspection report
After each inspection we produce a report about the service. This presents a summary of our findings and judgements. The report focuses on what our findings mean for survivors using your services. It gives details of our judgements on whether services are providing people with support that is safe, effective, caring, and responsive, and whether the service is well-led.
When we find examples of good practice during the inspection, we describe them in the report to support learning and improvements. Our reports will also identify any areas for improvement and may contain associated recommendations.
Making judgements
Unlike the registered services that CQC regulates, we do not have the legal powers to require providers of safehouse or outreach services to make improvements.
However, the inspection team will make a judgement on whether your service is meeting expectations. This is based on our assessment of the evidence we gather against our KLOEs during the site visit, from the PIR, and from what survivors and other stakeholders tell us. Our judgements will also be influenced by the requirements of the MSVCC contract, which are cross-referenced to the KLOEs within the inspection framework.
When making our judgements, we consider the weight of each piece of relevant evidence. In most cases we aim to verify our evidence with other sources to support our findings. When we have conflicting evidence, we will consider its source, how robust it is, and which piece of evidence is the strongest. We may conclude that we need to gather additional evidence or get specialist advice to make a judgement.
When we identify areas for improvement, we will usually make improvement recommendations in our report. The timescales that we recommend in which to make improvements will depend on the seriousness of the issue and the associated risk, and will take into account MSVCC requirements.
If we identify serious concerns, we will send you an ‘early outcome letter’ shortly after our inspection. This will set out the nature of our concerns in detail and we will send a copy to the Home Office and the prime contractor.
Quality checks
Before finalising our reports, we check the quality and consistency through agreed internal assurance processes to ensure that our judgements are consistent.
Factual accuracy check
When we have completed and checked the quality of the draft inspection report, we will send you a copy to review. We will ask you to check the factual accuracy and completeness of the information that we have used to reach our judgements. The factual accuracy checking process allows you to tell us:
- where information is factually incorrect
- where our evidence in the report may be incomplete.
The factual accuracy process gives inspectors and providers the opportunity to ensure that they see and consider all relevant information that will form the basis of CQC’s judgements. The factual accuracy process does not deal with complaints about CQC or challenges to proposed recommendations.
We will send the draft report to you by email. Our email will include:
- a copy of the draft report
- a factual accuracy form for you to submit a response to CQC
- instructions about the deadline to send any comments.
Once you have received the email with the draft report, you have 10 working days from the date of the email to return the form with any comments. You are responsible for making sure that the factual accuracy of the draft report has been checked by the appropriate person and that any factual accuracy comments regarding the draft report have been approved and submitted.
The draft report includes the draft judgements. If the inspector corrects any factual details in the report or accepts any additional evidence, they will amend the draft report. They will determine whether this has an impact on a judgement and will explain any changes in writing.
If you do not wish to submit a response, please tell us immediately. We will then be able to finalise your report.
How we share inspection information
Once the factual accuracy of the inspection report has been agreed, we will email a copy of the final report to you, as well as the Home Office and the prime contractor. We will not publish inspection reports for Safehouse and outreach services on CQC’s website or make them available to the public. This is because of the confidential nature of these services.
Independent report on the services provided to survivors
In addition to service-level inspections, our agreement with the Home Office required us to publish a report on our initial findings from the inspection programme and through engaging with providers and other stakeholders. We published a report in January 2023 which focused on the themes we identified around survivors’ experiences and included examples of good practice and details of any areas where improvements were needed.
We may publish further independent reports in the future if requested by the Home Office.
Governance of the inspection regime
We will have regular meetings with the Home Office and the prime contractor to monitor how the inspection programme is being carried out.
Complain about CQC
We aim to provide the best possible service, and we welcome your feedback to help us improve our services and ensure we are responding to your concerns as best we can.
If you have a complaint, see the Complain about CQC section for more detail.
Inspection schedule for safehouse and outreach services
This timeline provides a guide to our activity during the inspection process.
Activity: We will telephone providers to announce our inspection.
Timescale: 10 working days before the inspection.
Activity: We will email providers a letter to confirm the inspection and a provider information return (PIR) form.
Timescale: 10 working days before the inspection.
Your staff should use this period to return any requested information and offer survivors an opportunity to give feedback through the survivor survey.
Activity: We carry out the on-site or remote inspection of safehouse/outreach services.
Timescale: The duration of the inspection will depend on the size and geographical spread of your service(s). We will confirm this when we telephone you to announce the inspection.
Activity: The provider submits any additional information (if we ask for it).
Timescale: Up to 7 working days after the inspection.
During this time, we draft our report and complete internal quality assurance processes.
Activity: We send the draft inspection report to the provider by email for factual accuracy check.
Timescale: 20 working days after the end of the on-site inspection.
Activity: Deadline for the provider to return factual accuracy comments.
Timescale: 10 working days from the date you receive the draft inspection report.
We consider your comments and amend the report if we accept them, and review by independent quality panel if significant amendments or changes to our judgements are necessary.
Activity: We email final report to the provider, the prime contractor and the Home Office.
Timescale: On or before 50 working days after the end of the inspection.