Item 5
Paper No CM/01/13/04
Care Quality Commission
Board presentation – 7 February 2013
Developing a strategic framework to
guide CQC’s programme of
evaluation
Kieran Walshe
Professor of Health Policy and Management
Manchester Business School, UK
kieran.walshe@mbs.ac.uk
Overview
• A review of the current regulatory model
• Focused review of four areas:
– Differentiation in regulatory design
– Standard setting
– Risk assessment and proportionality
– The inspection workforce
• Comparisons with four other regulators – two in
healthcare in other countries, two in other sectors in
England – plus review of relevant research and
existing CQC data
Regulatory model: key issues
• Focused on “safety net” regulation with limited capacity
and capability to drive improvement
• Some inherent issues with generic model/approach;
QRPs and risk assessment; and information provision
• Likely to be low impact and VFM as it stands
• Strategic review indicates major changes in regulatory
model – particularly in improvement, differentiation
Comparison with four other regulators
• Joint Commission for the Accreditation of Healthcare
Organizations – main US regulator for acute care
• Inspectie voor de Gezondheidszorg (Dutch Healthcare
Inspectorate) – oversees healthcare organisations,
professions and technologies
• Office for Standards in Education, Children’s Services
and Skills – regulates/inspects schools, FE, early
years, childminding, children’s social services, etc
• Homes and Communities Agency – regulates providers
of social housing – “registered social landlords”
Differentiation in regulatory design
• All other multisector regulators differentiate – often
common methods and processes but tailored
standards, guidance, inspection staff, intensity of
oversight
• Rationale for differentiation – size/scale of sector,
complexity and level of risk in services, size/no of
providers, range of performance/heterogeneity
• CQC could pilot differentiation in/with one or more
sectors – probably the larger sectors with most
heterogeneity
Standard setting
• Variation in approach taken by other regulators but
tend to have standards that are specific to sector, are
more maximal or discriminating, and to involve sector
in framing/setting standards
• CQC could pilot the development and use of tailored
guidance based on existing standards (building on
experience of themed inspections) and pilot use of
standards from other sources eg NICE
Risk based regulatory approaches
• Other regulators - risk assessment at sector/service
level common but risk assessment/targeting at
organisational level limited/problematic – data not good
enough to predict risk
• CQC could pilot a simplified form of risk assessment
based on its own inspection findings
• CQC could consider other uses for the performance
data collated for QRP – in providing/publishing
information
The inspection workforce
• Inspectors need competence in three domains: content
knowledge, regulatory process, and interpersonal skills
• The professional judgement and “people skills” of
inspectors are very important – other regulators all use
senior, experienced and qualified staff and invest in
their training/development
• CQC could audit the existing content and regulatory
expertise of its inspection workforce, and pilot
specialisation in one sector or with some inspectors
• CQC could develop a more formal and extended initial
training and continuing professional development
programme for inspectors
Conclusions
• Scale and pace of change in regulatory model
envisaged by strategic review
• Can pilot important changes quite quickly – use
scale and capacity of CQC
• Need to test and evaluate changes as they are
developed and before they are rolled out
• Should use CQC’s routine data set to provide
ongoing measures of impact and effectiveness