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King's Fund on Changes to CQC

The King's Fund has responded as follows to a consultation on proposed changes for the Care Quality Commission (CQC).

The CQC has been under extremely intense national scrutiny in recent months and years, and overall we support its proposed new strategic direction. We are concerned that there is a broad public expectation that the CQC could and should be able to provide absolute assurance to the public that all health, mental health and social care services in England are safe and effective. While it is undoubtedly essential that the CQC continues to develop, test and refine the most effective possible mix of regulatory activities to fulfil its role, it is important to accept that quality regulation can only be the third line of defence against serious quality failures. 


The first line of defence is frontline professionals, both clinical and managerial, who deal directly with patients and carers and are responsible for their own professional conduct and competence and for the quality of the care they provide. They are first-hand witnesses when things go wrong and often have ideas about how the quality of care could be improved. It is vital that they are able to speak up and are empowered to act to prevent failings in care. The second line of defence is the boards and senior leaders of providers responsible for ensuring the quality of care delivered by their organisations. 

They are ultimately accountable when things go wrong and should be able to address problems that arise because of a lack of systems and processes. It is vital that they are able to monitor the quality of care, take action to resolve issues, and create a culture of openness that supports staff to identify and solve problems. The third line of defence is the external structures and systems, usually at national level, responsible for assuring the public about the quality of care, which includes the Care Quality Commission.

For the Care Quality Commission to be most effective it is essential that its work is proportionate, and so supports both frontline staff to deliver high-quality care and to act to prevent failings, and supports boards and leaders or organisations to focus on quality. There is a risk that the regulatory requirements of external bodies crowd out a focus on the effectiveness of internal quality governance arrangements and that the activities related to fulfilment of these requirements run counter to an organisational culture that promotes learning and improvement. The King's Fund comments on the consultation are made with this overarching principle in mind. The comments cover:

  • inspections
  • ratings
  • the involvement of and provision of information for patients and the public
  • whistleblowing
  • thematic work and investigations
  • working with Monitor and other national bodies
  • the CQC’s role in quality improvement
  • the proposals for intelligent monitoring and the tier one indicator set

For the full response to the consultation (pdf), click here.

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