By Kieran Seale and Peter Kinsey
There are lots of ways in which people would like to respond to an unfavourable report on CQC compliance – not all of them printable in a polite blog. But what actually is the right way to respond?
We have been thinking about this question as we work with a client which received a CQC inspection a few months ago.
We were particularly focused on the question of whether the organisation was ‘well led’, and what it means to be a well led organisation.
There are, of course, lots of things to think about in the guidance – vision, leadership, people, systems, etc. Before thinking about those, however, you need to ask yourself if you know how well led you really are. By definition, those that are worst led have the least awareness of this. But it is often very difficult for any organisation to see itself objectively.
Without objectivity, challenging the CQC is fairly pointless. But even with a degree of awareness, simply challenging the words that the CQC have used in their compliance report can also be fruitless – for two other reasons.
Firstly, it is quite difficult to change people’s minds about what they have already written. They will have thought about it and (hopefully!) had it checked before it is sent out. You will need something compelling to get them to think again.
Secondly, how does arguing about words help anyone? It certainly doesn’t improve the service patients receive. More fundamentally, it doesn’t demonstrate compliance to the CQC in terms of being a well led organisation.
So how do you demonstrate that you are well led?
Clearly you need evidence, and you can prove some things with board minutes and committee structures. But it is hard to prove many of the more subjective elements in this way.
Maybe it is helpful to think about the problem like this: if you were giving feedback to someone about how their organisation was run, what would you want them to say in response? We think that it would be something along these lines:
- Thank you for your feedback. We have considered carefully what it means for our organisation.
- We think that you missed (or got wrong) the following things about our organisation.
- While we might not agree with the particular points you make about how we are run, we have been reflecting on these issues ourselves. We know that we can always learn and improve things and this is what we have underway to improve in these areas.
Many organisations bring in advisors at the last moment to help them to “respond” to the CQC. How useful is a last-minute response, really? What effect will it have on compliance? For the organisation we have been working with we have spent some weeks talking to them about how they are governed and how they can improve. Some of the things we identified were the same points as the CQC ones, while some were completely different! But this process meant we could give them information for a focused response to their inspection report.
More importantly it meant that we could give them useful feedback for the longer term – to help the organisation move forward in light of CQC compliance and genuinely improve how they are run.
Real improvement, of course, is the only thing that will genuinely make a difference to ratings in the long term. And improving the way organisations are actually run is, of course, the real point of the whole process!
Verita work collaboratively with organisations to develop policies and procedures, systems and infrastructure in order to address compliance concerns. If you’d like to find out more about the CQC compliance support we can offer, please book a free consultation or contact Ed Marsden on 020 7494 5670 or [email protected].
Kieran Seale is a director at Verita.
Peter Kinsey has worked in health and social care for 35 years. Most recently he was Chief Executive of ‘Achieve together’, one of the largest learning disability provider organisations in the UK. Peter led the successful merger of CMG and the Regard Partnership to form Achieve together.