Having suspended its inspection regime in March following the COVID-19 outbreak, CQC has now launched a new Emergency Support Framework  (ESF).

Under the framework, inspectors will set up a one hour online meeting with managers/nominated individuals, to discuss the stresses and challenges services are experiencing during the COVID-19 pandemic. They also want to hear about the innovative ways providers have developed to meet these challenges. CQC is emphasising that the conversation is a two way process and its aim as a regulator is to provide support to providers at this time. CQC will prioritise calls with high risk providers in the first instance. We explore the key features and what this means for you below.

What will be discussed?

The conversations will centre around four key areas:

1. Safe care and treatment
2. Staffing arrangements
3. Protection from abuse
4. Assurance processes, monitoring and risk management.

The inspector will then provide a written summary of the discussion, in PDF form, setting out:

• The discussion around the four questions
• The internal and external risks faced by the provider
• Any sources of support CQC are suggesting
• And a conclusion of whether the service is “managing” or “needs support”.

In a recent webinar presented by the CQC, it stated that the support it can give will mainly be signposting organisations to other bodies who can help with an issue (for example obtaining PPE; support for staff).

Will the ESF impact my rating?

This is not a formal CQC inspection and so no rating will be given and the discussion will not impact a current rating. Further, the PDF of the discussion will not be published on the CQC website and will not be disclosed to other organisations. If they find serious concerns during calls, then CQC could undertake a focused inspection or, in extreme circumstances, take regulatory action.

What do we need to do?

Whilst CQC is saying the ESF is a helpful discussion and is being presented as a somewhat informal chat between provider and inspector, in our view it is important that the discussion is treated as a formal CQC process. Providers should make sure they’re prepared for the discussion around the four questions and be prepared to provide documentary evidence to CQC if necessary. It is also important to carefully check the pdf that’s sent through to make sure that it reflects the discussion fairly. Whilst the summary of the discussion is not subject to the factual accuracy process, it is still vital to clarify an error in the summary with the inspector by email following the discussion.  Hopefully this will lead to a change to the summary but, if not, having a record of your challenge to the accuracy of the record, should it be raised later on as an issue, will be very important.

How can Capsticks help?

Capsticks specialist CQC advisory team have unrivalled experience in supporting NHS Trusts, Independent Health Providers, Care Homes, Online Digital Providers, GPs and Dentists with all issues in respect of CQC and a proven track record in delivering successful outcomes for our clients.

If you have any queries around the ESF or any wider CQC issues or concerns, please speak to Siwan Griffiths, Ian Cooper or any of your contacts at Capsticks.