Key points to share from CQC Learning Disability and Autism experrt advisory group – 22 May 2015 – Pete Cross, Head of Strategy and External Communications, Autism Care (UK)
- Emphasis on Inclusive Communications and Inspection Methodology.
- CQC have drafted new pre inspection information requests (from provider) for learning disability services – these have been based on pilot with substance services.
- CQC are developing more robust ways of inspecting autism services – may look at pathway tracking (e.g. how people move between services). Also developing new guides, templates and tools for inspectors – currently being piloted so some providers may have seen these.
- CQC have produced new ‘brief guides’ for inspectors – these are currently going through approval process, and further guides will be written by new CQC learning disability policy manager (theses such as restraint, blanket restrictions, communication, psychoactive medications, discharge planning, general care planning, autism, positive behaviour support). These are short reference guides (maximum of 2 pages). Once guides are signed off they will be publicly available for other stakeholders to reference. Will likely go on provider portal once launched in June).
- Also producing case studies in some areas as part of training for inspectors (online development academy) and a specific brief guide is being produced on seclusion, rapid tranquillisation and mechanical restraint – especially for people not subject to MHA. Some structure changes in CQC – New 1 year fixed term learning disability policy manager post (appointed but not started, may be renewed), reporting to head of Adult Social Care.
- Inclusive Communications Work stream are looking at how tools can be embedded. Looking at a senior level at how this work is being taken forward.
- Further guidance to be published on inspection of independent sector healthcare services (hospitals, including secure environments).
CQC Engagement Directorate update – linking engagement work to the wider work of the transforming care delivery board
1. Confirm an overall narrative as to CQC’s role in the lives of people with learning disabilities.
2. Better engagement with providers, explaining the development of inspection methodology etc (including better understanding the differences between NHS and independent sector)
3. Looking to better engage with voluntary sector groups who work with and support people with learning disabilities, and trying to better engage with local Learning Disability Partnership Boards, advocacy and self advocacy services.
This will include better informing these groups about upcoming large inspections (hospitals etc).
4. Continue to run experts by experience programme (across all inspectorates) this is being re-procured at a significantly larger volume so there will be more EBE’s in coming months and year. Would welcome views on how experts themselves are supported.
5. Better public information about standards of care and what people using services should expect – this will include targeted information for people with learning disabilities and autism. Also more accessible inspection reports for the new regulatory regime (long term piece of work).
6. Feel that currently not enough work done with families / individuals in the context of the inspection of community based services (and indeed a wider issue as to how supported living sits in a regulatory context within dom care)
Current CQC priorities
- Better monitoring of DOLS and new training for CQC staff .
- Encouraging whistleblowers (see ‘Complaints Matter’ report published December on CQC website).
- Improving inspections of ‘high risk’ services. Role of expert advisory groups is part of this work.
- Increased focus around regulatory action around the theme of consent and where this is not taken into account.
- Prompt and robust action for failing providers (civil and criminal actions). Specific guidance will be produced for learning disability services (and will come to this group for feedback). Will also cover CQC works with local commissioners where people need to be moved and how this is planned, especially in terms of people with autism. Perhaps the overall methodology around this issue should be the same for social care providers as for hospitals. This will include pathway tracking of individuals who come out of long stay hospitals.
- Changes to ‘fit and proper person’ now being rolled out.
- Learning Disabilities Programme Board being set up: New board (internal) 1 year – cross cutting CQC work streams. Also looking at how CQC makes best use of its insight / intelligence / data in terms of specific providers, and enforcement and responsibilities as regards approach to service closures. Looking broadly at experiences of people with learning disabilities across a range of inspected services. Will include things like learning disability champions in primary medical services, for example looking at the extent to which GP’s do annual health checks . Needs to link to EAG and Transforming Care Group. The first board meeting took place on 21st May, and there will be weekly meetings, and a biannual report to CQC Executive group
- Learning disability will feature more prominently in this years ‘State Of Care’ report – what would be useful themes to report on?
Transforming Care update
- Cited Bubb report / public accounts committee as to CQCs role as market entry regulator for inpatient services
- Transforming Care /Winterbourne Delivery Board (made up of concordat partners)
- 5 work streams now fully established and these are:-
1. Right Care Right Place (lead by NHS England)
2. Empowerment and Advocacy ( DoH)
3. Data and Information (NHS England)
4. Workforce (Health Education England)
5. Inspection / Regulation (CQC, Paul Elliot)
- CQC is looking specifically at inspection methodology, as well as registration issues and service model. Not up to CQC to specify bed numbers without a comprehensive policy framework / context. Also looking at the issue of care close to home. Acknowledgement that this needs to be a clearer more structured process (including what will be registered as well as what will not). This will include lots of smaller registrations in close proximity (‘campus by the back door’). Also looking for positive evidence as to models that work / deliver positive outcomes. This includes scoping what works as alternative to inpatient models.
- Exploratory work as to how supported living is looked at (especially for people with more complex needs).
- Discussion re regulation of commissioning and CLDTs. This is a gap in the system.
- A Head of Market Oversight within CQC Adult Social Care has been appointed to look at clearer messages to the market about what models are seen as effective and how this would connect to new registrations in particular. Where local commissioning is an issue CQC are able to commission an investigation, but do not have enforcement powers.
- There was a consensus about providing advice to CQC on range of learning disability and autism issues. This will link to the wider CQC project board for learning disability and autism.
- Next meeting will be held at the end of July (date tbc) and may focus on reviewing brief guides, when Learning Disability Policy Manager is in post.