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Paper No: CM/04/12/07
MEETING:
PUBLIC BOARD MEETING
DATE:
20 NOVEMBER 2012
TITLE OF PAPER: ACCOUNTABILITY FRAMEWORK
SUMMARY:
To present to the Board the Accountability Framework which has been developed to help
clarify accountabilities from Board to Director level in CQC.
RECOMMENDED ACTION:
That the Board APPROVES the Accountability Framework for adoption and NOTES that
the Framework will be brought back to the Board for review in six months when the
Scheme of Delegation has been revised and the accountability arrangements on the
following issues are clearer:
 Decisions to be made by the Board and by the Executive Team
 The sources of assurance for the Accounting Officer’s responsibilities
 A review of the role of the Executive Team and its committees
Executive Decision/
Board for
information
Executive and Board
decision
Executive and Board
shared decision
The Executive Team has
made a decision and the
Board has been informed
The Board has been
consulted in order for the
Executive Team to make
a decision
This is a shared decision
between the Executive
Team and Board

Executive and Board
discussion/Board
decision
This is for when it is clear
that it is a specific Board
decision (under statutory
and legal requirements)
ie. signing off the annual
accounts
* Check box as required
LEAD DIRECTOR:
AUTHOR:
DIRECTORATE
DATE:
SUPPORTING
PAPERS:
Louise Guss, Director of Governance and Legal Services
Sue Martin
Governance and Legal Services
12th November 2012
Annex A – Accountability Framework
GOVERNANCE
AUDIT TRAIL:
The Accountability Framework has been developed
under the aegis of the Corporate Governance Framework
Project. It is a new product which aims to support the
Corporate Governance Framework approved by the
Board in May 2012 by mapping the Board’s
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accountabilities through the organisation to Executive
Team level.
LINK TO STRATEGIC
OBJECTIVES AND
BUSINESS PLAN
The Accountability Framework is intended to support the
Business Plan objective 3 to strengthen CQC’s
governance to be a high performing organisation.
IMPLICATIONS FOR NCSC
No particular implications for NCSC.
FINANCIAL IMPACT:
There are no particular financial implications.
RISK IMPACT:
The DH Performance and Capability Review found that
accountabilities between the Board and the Executive
Team were blurred. Without a clear statement of
delegations (under review) and accountabilities, there is
potential for confusion as to who is responsible for what
and how accountability should be discharged. The
Framework also demonstrates the complexity of
accountability arrangements in CQC, which is a risk for
both the Board and the Accounting Officer who are held
to account for the delivery of CQC’s objectives by
Parliament. Further work is needed to clarify the Board’s
information needs to support its decisions, which will be
presented to the Board in due course.
REPUTATION IMPACT:
The Accountability Framework will help to demonstrate
that CQC is addressing the criticisms made of its
governance by both external bodies and internal audit.
As part of the Corporate Governance Framework Project,
Internal Comms and Learning and Development are
considering how to communicate the Framework to staff
in an accessible way to promote greater understanding of
the governance framework.
The Accountability Framework takes account of CQC’s
current legislative responsibilities but will need to be
updated to take account of new requirements when these
are clear, for example the National Information
Governance Committee. The DH Framework Agreement
which is the source of a number of the Board’s
accountabilities is still in draft. The Accountability
Framework will need to be reviewed to ensure it complies
with the Framework Agreement when it is finalised and
signed by the CQC Chief Executive.
LEGAL IMPLICATIONS:
HEALTHWATCH IMPACT:
The role of the Healthwatch England Chair has been
included in the Accountability Framework. The HWE
Committee may consider mapping its accountabilities in
due course when it has been established.
EQUALITY IMPACT
ASSESSMENT:
An equality impact assessment is not applicable and has
not been completed.
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1. Background
1.1 The most recent Internal Audit report on CQC’s governance arrangements found that
there was a lack of clarity about the respective roles, responsibilities, accountabilities
and boundaries of the Department of Health, the CQC Board and the Executive Team.
The report commented that accountability was blurred and needed to be more rigorous
and transparent at a strategic level and then cascaded through all the supporting
structures and processes. A similar finding was reported by the DH Capability and
Performance Review.
1.2 The Accountability Framework (AF) has been developed, under the aegis of the
Corporate Governance Project Board, to begin to address these findings. It remains
“work in progress” but is now a sufficiently complete map of the current position to be
tested by staff to see where accountabilities need to be further clarified.
1.3 The views of ARAC have been sought by email and their comments have been
incorporated into the current version of the Framework. Those members who
responded were generally supportive of the document but asked that the source of the
accountabilities, particularly those for the Board, be referenced. This has been done.
1.4 A review of the CQC Scheme of Delegation is in hand to ensure that the two
documents align. It will be presented to the Board for approval in the new calendar
year.
2. Executive Summary
2.1 The Accountability Framework aims to demonstrate how CQC discharges its
responsibilities, first and foremost to Parliament and DH. The starting point is the
analysis of the responsibilities of the Board, as specified in the revised DH Framework
Agreement, and of the Chief Executive as Accounting Officer and head of the executive
function. The AF takes each of the Board’s responsibilities, identifies what the Board
needs to do to discharge those responsibilities, and who provides the necessary
information and assurance to the Board to enable it to do so. The same process has
been followed for the Chief Executive’s responsibilities as both Accounting Officer and
Chief Executive. The accountabilities have been tracked back through the organisation
to Director/Executive Team level, as far as possible.
2.2 The Accountability Framework shows the complexity of accountability arrangements in
CQC. These are in part a function of the breadth of responsibilities which the Board
and the Accounting Officer have. The Chief Executive is a member of the Board and
accountable to Secretary of State and the Chair as a Board Member; is the chief
executive officer of CQC and accountable to the Chair for his performance; and as
Accounting Officer is accountable both to the Principal Accounting Officer in DH and to
Parliament for regularity, propriety and value for money.
2.3 There are several issues which could be clarified, however, to make CQC’s
accountability arrangements more transparent. These will be progressed over the next
six months and reported back to the Board. They include:


Reviewing what decisions need to be taken by the Board and those which can be taken
at Executive Team level
Ensuring alignment between the Accountability Framework and the Scheme of
Delegation which is under review and will be presented to the Board for discussion
shortly
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


Clarifying further what information (eg on risk or performance) is required at different
levels of reporting (eg Board, ARAC, ET) to reduce any unnecessary duplication of
reporting
Clarifying the sources of assurance for the AO. Work is in hand to improve the level of
assurance provided to the Board and the AO: arrangements for proper programme
appraisal are being developed; the procurement policy is being reviewed to ensure it
captures all projects which might impact across CQC; better management information
is being developed; and approval requirements for large-scale expenditure is being
addressed by Finance.
Reviewing the role of the Executive Team and its committees
2.4 Changes to the Committee structure will be incorporated into the Corporate
Governance Framework and then into the Accountability Framework as well as the
Scheme of Delegation, to ensure there is alignment between these products. Reports
will be brought to the Board to approve the proposed changes. Changes in
responsibilities will also be reflected in an updated Accountability Framework. The
Accountability Framework will be evaluated in six months as part of the Corporate
Governance Framework project and any revisions made at that time.
2.5 As part of the Corporate Governance Framework project, Internal Comms will map the
Accountability Framework with a view to demonstrating to staff how accountability
works throughout CQC and how their role fits in. Learning and Development will also
include some training on the AF in forthcoming sessions for the leadership team and
for business managers.
Conclusion
3.1 The Accountability Framework aims to address the criticisms made by external and
internal scrutiny reports that accountabilities in CQC are blurred. It remains “work in
progress” and will be reviewed and updated in six months, along with other key
governance documents.
4. Next Steps
The Board is asked to
 approve the Accountability Framework for adoption,
 note that the Framework will be brought back to the Board for review in six months
when the Scheme of Delegation has been revised and the accountability
arrangements on the following issues are clearer:
 Decisions to be made by the Board and by the Executive Team
 The sources of assurance for the Accounting Officer’s responsibilities
 A review of the role of the Executive Team and its committees
Name:
Title:
Date
Sue Martin
Corporate Governance Officer
12th November 2012
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CQC ACCOUNTABILITY FRAMEWORK
Purpose of the document
Accountability is an essential component of integrated corporate governance. A robust and
transparent Accountability Framework plays an important part in ensuring and assuring the
proper discharge of the organisation’s responsibilities.
The purpose of this document, which supports CQC’s Corporate Governance Framework,
is to set out who has responsibility within CQC for discharging its key functions and what
assurances they rely on so that business is conducted in an efficient, effective and
economical manner1 without duplication of effort but also without missing key
requirements.
What does accountability mean in CQC?
Parliament has conferred through legislation specific responsibilities on the Care Quality
Commission as the independent regulator of health and social care in England. CQC is
held to account as an organisation for the way in which it discharges its responsibilities by
the Secretary of State for Health on behalf of Parliament and, in the case of the
Accounting Officer, directly by Parliament as well as by the Principal Accounting Officer in
the Department of Health. CQC is required to report to Parliament to satisfy it that the
public funding CQC has received has been well and appropriately spent and it has
delivered the objectives CQC has agreed with the Department of Health2.
In the Framework Agreement between DH and CQC, the Department of Health has given
specific responsibilities to the Chair of CQC, the CQC Board, the Healthwatch England
Chair, and the Chief Executive.
The diagram below (from the Framework Agreement) sets out the accountability
relationships between Parliament, Secretary of State for Health, the Chief Executive and
the Board.
While the responsibility for discharging CQC’s functions rests ultimately with the CQC
Board and the Chief Executive, their responsibility is shared across the organisation. Each
Committee, Directorate, Team and individual role-holder has certain delegated
responsibilities, for which they must answer. Accountability therefore also sits at
Committee, Directorate, Team and individual level.
1
2
Health and Social Care Act 2008 Schedule 1 para 2.3
Requirement in the DH Framework Agreement
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Parliament
SECRETARY OF STATE
Overall accountability for the
health and social care services,
including overseeing
CQC and holding it to account.
DH PERMANENT SECRETARY
Accounting Officer for DH, responsible
for the overall system of control in the
NHS to ensure proper use of public
money and stewardship of assets
Delivering Minister’s decisions and
supporting Ministers in making policy
decisions.
HWE CHAIR
Strategic
leadership,
direction and
guidance of
HWE .
Performance
against
objectives
and strategic
priorities.
CQC’S CHAIR on behalf of
BOARD
Strategic leadership, direction
and guidance of CQC.
Performance against
objectives and strategic
priorities.
CQC’s CHIEF EXECUTIVE
Accounting Officer for CQC and HWE as
designated by the PAO, responsible for
the day-to-day system of internal control
for CQC to ensure proper use of public- money and stewardship of assets.
Direct
relationship
through
laying of
annual
reports and
accounts
and
committee
hearings
Operational delivery against CQC’s objectives and
strategic priorities
An effective Accountability Framework
There are six elements underpinning a robust and transparent framework of accountability.
These elements operate at both the organisational and individual level.
1. Clarity about roles and authority
There needs to be clarity about who holds what roles, their responsibilities and the level of
authority associated with those responsibilities.
If there is clarity about who has the necessary authority, for example to make decisions,
decision-making and delivery of key tasks will be more effective and risks will be able to be
managed at the most appropriate level.
In CQC, clarity around roles, responsibilities and authority is provided by:
 The DH/CQC Framework Agreement which sets out DH’s accountability
requirements of CQC
 Organisation charts which are up to date and show who reports to whom
 Terms of reference for all committees which are up to date and regularly reviewed
 Scheme of delegation which is regularly reviewed and up to date
 Board training and induction programme which ensures awareness of the Board’s
role and accountabilities
 Training and induction programmes for each employee or person working for CQC
which ensure understanding of their role, responsibilities and accountabilities
 Clearly defined ownership of the Corporate Governance Framework, clear
responsibilities for governance, and commitments to improve
 Clearly defined governance structure with map
 Job descriptions, performance appraisal arrangements and work objectives
 Accountability statement (attached), showing how risks and issues are escalated
through the organisation
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2. Commitment to values
Those to whom roles, responsibilities and authority are delegated are expected to
demonstrate a commitment to carry out their roles and responsibilities in accordance with
the behaviours, ways of working and values of CQC.
With this commitment, decisions will be made in accordance not only with statutory
requirements but with the standards of ethical conduct and behaviour expected and
accepted by CQC, and the values and principles governing the organisation.
In CQC, commitment to the standards and values to which CQC aspires is secured
though:
 Codes of conduct for Board Members and for staff
 Letters of authority from the Chief Executive to Directors which set out their roles,
responsibilities, level of delegated authority and standards expected of them
 Job descriptions and PDR objectives which confirm what staff are expected to
deliver and to what standard, and the support they will receive to deliver those
objectives
 HR policies which set out clearly how failure to meet the standards expected of
people will be handled
 Business policies and processes that set out how CQC’s business should be
conducted and to what standard, including:
o business planning including monitoring of strategic and operational plans and
budgets
o financial management
o HR strategies, policies and procedures
o performance management framework
o Risk management process
o Business continuity arrangements
o Project and programme governance
o whistle-blowing
o compliance with statutory requirements including health and safety at work
and information security, including a code of practice on confidential personal
information
o Media handling process to deal with reputational risk
 Monitoring processes which confirm that the standards of business processes are
being met
 Template on decision-making which confirms that decision support the values and
principles of the organisation, as well as taking account of financial and legal
considerations
3. Formal reporting
Those to whom roles, responsibilities and authority have been delegated are required to
report formally to whoever has delegated the responsibility on how they have discharged
their functions.
Through formal reporting of performance against business plans, the budget and
compliance with CQC policies, CQC can demonstrate that it has delivered its objectives in
the right quantity, to the right quality, on cost and on time.
Within CQC, formal reporting from those to whom authority is delegated is provided
through:
 Annual report and accounts which are laid before Parliament
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












The Annual Governance Statement which is signed by the Chief Executive as the
Accounting Officer
Publication of statutory reports eg on the delivery of CQC’s responsibilities under
the Mental Health Act 2008
Statutory disclosures to Parliament and to other statutory bodies such as the
Information Commissioner, the Parliamentary and Health Ombudsman
Evidence to scrutiny bodies such as the National Audit Office and Parliamentary
Select Committees
As part of the preparation of the Annual Report and Governance Statement,
statements of assurance from Directors to the Chief Executive to account for how
they have delivered their responsibilities, how they have performed against
objectives, how they have used their resources and how they have responded to
risks
Quarterly reports on performance to the Department of Health
Quarterly reports from the Executive Team to the Board on performance
Monthly performance reporting to the Executive Team against the scorecard
Weekly performance reporting to the Chief Executive
Staff self-assessment as part of the PDR process
Self-assessment by Committees and the Board of their effectiveness
Full and exception reports from Board Committees to the Board to account for the
delivery of their work-plans
Reports from Head of Internal Audit
Reports on any internal control failures or poor risk management
4. Well-informed challenge
Well-informed challenge by the person or committee who receives the report enables them
to seek to verify that what has been reported is correct.
Those who delegate responsibility need to have sufficient understanding of the issues to
be able to challenge and scrutinise effectively.
In CQC the ability to question and challenge is supported by:
 Appearance by the Chair and/or the Chief Executive before Parliamentary Select
Committees
 Attendance by the Chief Executive at Quarterly Accountability Reviews with DH,
supported by a schedule of regular meetings between DH and CQC to discuss
strategic, planning and accountability issues
 Role description of Non-Executive Directors on the Board which gives them
particular responsibility for scrutiny and challenge of management plans and
information
 Performance reporting at all levels within the organisation
 Management information which supports analysis of the performance scorecard
 Management assurance processes which involve ongoing checking, validation and
monitoring by managers and others
 Reports from whistleblowers and complainants
 Within the appraisal process, the manager has the opportunity to verify the selfassessment
5. Independent validation
The reports provided by those to whom authority has been delegated should be able to be
independently validated, where this is appropriate and cost-effective.
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Those who delegate responsibility may from time to time seek independent validation, for
example through internal audit, of the reports they have received to confirm the accuracy
of what has been reported.
In CQC, options for independent validation are provided by:
 Internal audit
 External audit
 External reviews eg by HM Treasury, DH Performance and Capability Review, NAO
thematic reviews
 Use of Gateway review process and other quality checks
 Scrutiny by Audit and Risk Assurance Committee
Independent validation may be continuous or episodic. Continuous validation may be
undertaken by secondary checking or by external feedback eg from those who have been
inspected.
6. Linkage with rewards and sanctions
There should be a clear and demonstrable linkage between the rewards and sanctions
provided and levels of responsibility and authority.
Everyone within CQC should be clear about how the performance of roles and
responsibilities links to the rewards and sanctions provided by CQC. In order for CQC to
be a high performing organisation with a strong learning culture, managers are expected to
take responsibility for helping their staff to improve their performance through regular
performance monitoring, through development opportunities and effective succession
planning.
In CQC, the linkage between roles and rewards and sanctions is provided by:
 Policy on performance pay
 Policy on payment of allowances
 Codes of conduct
 PDR process
 Capability procedures
CQC Accountability Statement
The accountabilities of the Secretary of State and the Principal Accounting Officer to
Parliament are set out in the DH Framework Agreement3.
This Accountability Statement (attached) focuses on accountability within CQC and
summarises
 Who has been given delegated responsibility, by whom and for what purpose
 Where the role-holder or Committee gains the information and assurance they need to
satisfy the person or body who has delegated the responsibility and who holds them to
account
 How the role-holder or Committee are held to account
It explains how the accountabilities which the Board and Accounting Officer have to
Parliament are discharged and the information they rely on to do so. These
accountabilities are then tracked back through the organisation to show the links in
accountability through the organisation.
3
The DH Framework Agreement sets out how the Department holds CQC to account
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