Timetable for change
|Roll out||August 2022||[Unknown]|
|Online Provider portal||September 2022||Summer 2023|
|Pilots for new assessments||October 2022||[Unknown]|
|Start new assessments||January 2023||End of 2023|
|KLOEs cancelled||January 2023||[Awaiting clarification]|
Quality Statements replace KLOEs
This is a ground up redesign starting from the bare bone Domain Headings of Safe, Caring, Responsive, Effective, and Well-Led.
- The Key Domains have new definitions
- Each Domain has 5-8 Quality Statements (34 in total)
- Evidence will be gathered in 6 pre-defined categories
[Note that KLOEs are scrapped in their entirety]
Transition from old to new
There was a gap during this transition in 2023 where the KLOEs were scrapped but the new Quality Statements would not be in place until the end of 2023.
The CQC has since clarified that KLOEs will now remain in place during this period. There is no "transitional arrangement" as yet and Providers are expected to follow KLOEs until the last day.
In the absence of a transition arrangement, technically, every Provider would risk non-compliance on day one of the new regime, as they prepared evidence based on KLOEs but the inspector is now applying the new Quality Statements to judge compliance.
Our recommendation for 2023
- If you have been rated "Good" or above, you will already be KLOE compliant, so as long as you have maintained good standards, you will remain compliant
- If you are compliant with KLOEs, you will also likely be compliant with most Quality Statements
- Our recommendation is to start implementing the new Quality Standards now so that you are ready on day one of the new regime.
New ratings methodology
Each Quality Statement will be assessed based on 6 predefined evidence categories
- People's experience of health and care services
- Feedback from staff and leaders
- Feedback from partners
This will provide a structured assessment system, injecting some level of consistency where none existed before.
Providers will also be able to pinpoint exactly how they fared in each area.
Evidence - What's New?
Look at the Evidence Categories carefully. You cannot prepare for any of these at the last minute
This is why:-
- Most categories are about gathering external evidence from stakeholders
- Only TWO are about evidence that you can provide (Observation and Processes)
- ALL are about looking at historic actions, events, and outcomes
Inspections have always been about historic compliance. If you haven’t been doing this throughout the year, you’re in difficulties.
All you can do at the last minute is gather your documents, you can't invent evidence
Evidence, Ratings, and Continuous monitoring
External evidence will be gathered on an ongoing basis, and your ratings can change at any time if this shows a change in risk.
What evidence is relevant and how assessments will be made will be tailored to different types of providers and services. The evidence will be scored, and this scoring used to determine the overall rating.
The overall emphasis is on continuous monitoring. The key takeaway for Providers is to ensure they have processes that also record evidence of daily compliance so that they are ready for inspections at any time.
The most positive takeaway is that ratings can be changed at any time: so a negative rating isn't that drastic. A Provider will have ample opportunity to fix things and get the ratings revised.
Policies Vs Processes
Processes have a new and separate heading; Policies are hardly mentioned.
A new focus on Processes. The CQC will be look for actual processes and activities, and not your impressive library of policies.
“Processes are the series of steps, or activities that are carried out to deliver care that is safe and meets people’s needs.
Our assessment focuses on how effective policies and procedures are. We will look at information from the provider and data sources that measure processes”
Note the wording "how effective" policies are, not that you "have appropriate" policies.
Their examples include clinical data, waiting times, care records etc. but not policies.