The CQC framework is changing. Again. Here is why the basics still matter.

If you have been keeping up with the latest CQC updates, you will know that the Single Assessment Framework is being replaced by four new sector-specific frameworks. Scoring is being removed. Quality statements are being replaced by a new set of key lines of enquiry, with rating characteristics making a comeback.

For anyone who has been in the sector for a while, this might feel familiar. That is because, in many ways, we are heading back to where we started. Before the Single Assessment Framework, we had key lines of enquiry, prompts and rating characteristics. Many of us valued that approach because it was simple to read & understand. As a registered manager, I could look at the framework and know exactly what my service needed to demonstrate.

The new draft framework leans back into that structure, which I welcome. But I will be honest, some of the proposed wording still carries elements of the Single Assessment Framework that have been criticised for being complex & unclear. There is more work to do before this lands as cleanly as it should.

The scoring debate

One of the bigger changes is the removal of scoring, with judgements moving back to professional judgement at key question level. I have mixed feelings about this.

The scoring system was not perfect, but it gave providers something useful. You could see exactly where you needed to improve. It pushed inspectors to apply ratings consistently because the scoring had to be evidenced and explained. And critically, it allowed for nuance. A service could have a few areas needing improvement within a key question without that automatically dragging the whole key question down to Requires Improvement.

Without scoring, there is a real risk we go back to seeing whole key questions pulled down over a single weak area. I have seen Safe rated as Requires Improvement because of one missing risk assessment or a gap in a medicine document, even when every other area was strong. That is exactly the kind of unfair outcome scoring helped to prevent.

How this plays out will really depend on the inspector on the day & how they apply professional judgement. Whether that brings the consistency they are aiming for, time will tell.

What is not changing

Here is the part that often gets lost in all the noise about framework updates. What good care actually looks like is not changing.

Underneath every assessment framework the CQC has ever used sit the Fundamental Standards. These are the standards below which care must never fall. They cover person-centred care, dignity & respect, consent, safety, safeguarding, food & drink, premises & equipment, complaints, good governance, staffing, fit & proper staff, duty of candour, and the display of ratings.

The Fundamental Standards do not change when the assessment framework changes. They are the legal baseline every provider must meet, regardless of how the regulator chooses to assess against them.

Whatever framework the CQC wraps around them, they will always look at:

• Medication management
• Infection prevention & control
• Risk management
• Safeguarding
• Mental Capacity Act & Deprivation of Liberty Safeguards
• Incidents, learning & improvement
• The environment, where applicable
• Care planning & risk assessments
• Working in partnership with other professionals
• Timely referrals & access to services
• Nutrition & hydration
• End of life care, where applicable
• Meaningful activities & engagement
• Staff training, competency & supervision
• Safer recruitment practices
• Visible, effective leadership
• Governance arrangements that identify issues, fix them & drive service improvement
• Kind, caring services that treat people with respect, dignity & support their individuality

These are not new expectations. They are the foundations of good care. They sit underneath every key question and they will sit underneath whatever the new frameworks look like once they are finalised.

Where to focus your energy

The frameworks have changed a lot in the past couple of years, and based on the draft proposals, we are not quite there yet. So my advice to providers is simple: do not chase every framework update. Focus on the fundamentals.

Benchmark your service against the current criteria. The new framework is essentially a streamlined version of what already exists, so working to today's expectations puts you in a strong position for what is coming. Get your evidence in order. Make sure your team understands what is expected of them. Update your tools, audits & systems to reflect current standards.

In my experience, most services are delivering good, kind care every day. Where providers tend to get stuck is not in the care itself, it is in evidencing it. The story of what your team does well is often there, it just is not being captured or presented in a way that reflects the quality of the work.

That is where the real preparation lies. Not in reacting to every framework change, but in building strong foundations that hold up regardless of how the regulator structures their assessment.

Need support?

If you would like to benchmark where your service stands before your next inspection, we can help. Whether you need a full mock inspection or a focused review of a specific area you are worried about, get in touch and we will talk through what works best for your service.

You can reach us at orobohealthcare.com/contact or email reece@orobohealthcare.com