Fortune Favours The Brave
A regular podcast for business leaders exploring how businesses can harness risks and use them to their advantage. In each episode Howden Insurance Brokers will discuss a topical challenge or issue and what business leaders can do to overcome it.
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Fortune Favours The Brave
The Care Quality Commission and how their ratings impact insurance premiums
Understand the Care Quality Commission (CQC) and the impact that their ratings system has on the insurance premiums of Care Home providers. Hosted by Richard Lawson, Senior Account Executive at Howden Health & Care.
With the expertise of Becky Garnett Buchma, Managing Director at Fulcrum Care Consultancy, and Sabrina Meetaroo, Head of Risk and Claims at Howden Health & Care, we provide guidance to help care home providers navigate the challenges of a CQC inspection process.
We discuss who the CQC are and examine the different ratings that a care home provider could receive from an inspection. We then delve into the impact that these ratings could have on care businesses; both from an insurance perspective and how the challenges that the CQC currently faces could lead to delays in reinspection.
Finally, we provide insights to help care home providers to prepare for a CQC inspection to ensure they can attain a higher rating and the insurance policies that providers should consider for their business.
Welcome to Howden's podcast Fortune Favors the Brave. We all take risks in our everyday life, and business is no different. In this podcast, we're speaking to the experts about a topical challenge or issue and what business leaders can do to overcome it.
Speaker 2:Hello and welcome to this episode of Fortune Favors the Brave. My name is Richard Lawson and I'm the Senior Exec here at Health and Care Howden. In this episode we'll be discussing the CQC. I'm joined by two guests today. First of all Sabrina. Hi, sabrina, could you introduce yourself?
Speaker 3:Hello Richard, I'm Sabrina Miteru. I am the Risk and Claims Advocate at Howden Health and Care. In my role currently, I am involved in being an advocate for our clients in terms of their risk management solutions and also their claims advocacy. My background is actually in healthcare. I am a qualified solicitor and have been for 16 years or so in all areas of health and care, so my family background is actually in social care. My parents, who are now retired, owned and managed a care home for 25 years, so I'm well versed in understanding the intricate dealings of social care, from regulations to managing risk, and currently I am involved in a social care provider for learning disability.
Speaker 2:Lovely, lovely to see you too, and also joining us is Becky, and Becky, if you'd like to introduce yourself.
Speaker 4:Hi, I'm Becky Garnett-Butchmer. I'm Managing Director at Fulcrum Care Consultancy. So we support providers to really sort of elevate standards and ensure that they are compliant with all the regulatory requirements and exceeding and really pushing forward the standards across the social care sector as a whole, and my background is very much health and social care. So I started out quite some time ago now as a support worker in a mental health inpatient unit for young people, went on to various sort of leadership roles within the sector, including providing complex care in the home and various other sort of roles within complex care settings. Yeah, so that's my background in a nutshell.
Speaker 2:And lovely to have you as well, Becky. It is a tradition here on this podcast that our guests tell us a time that they took a risk and it paid off. Is there something that you could share with us today?
Speaker 4:Yeah, actually you know what. It's sort of relevant to what we're doing today. So when I joined Fulcrum earlier this year, I had the opportunity to speak at some conferences so in particular Lung Busan, the national care show and I was really quite nervous. I've spoken a lot in front of internal teams, I've presented to external stakeholders, but I've never been up on stage as an expert talking about what I do. And I was on the stage at Lung Bison with some really high profile people from the sector and the industry and I'm not going to lie, my palms were sweating, my heart was racing and I was really nervous and sort of questioning if I was going to do a good job and what was it going to bring to the table. But actually once I got going, I thoroughly enjoyed it. I really enjoy being part of this sector. Every time I do a panel or something that pushes me out of my comfort zone, I always learn something new as a result. So yeah, I think that was a risk that paid off.
Speaker 2:That's wonderful. So we're here today to discuss the CQC and its role within the care sector. If we could start with you, rebecca, again just to provide an overview of what the CQC is and what it does and its role within the care sector.
Speaker 4:So the Care Quality Commission are our regulator, so they regulate health and social care and there's an underpinning legislation that we all have to adhere to, and the regulator are there to make sure that care providers are adhering to those regulations and to assess the compliance of providers and also to assess if people are fit to actually be registered as a care provider.
Speaker 2:So with that I would imagine there's a rating scheme within it. I mean, could you sort of expand on that and what they might mean to care businesses?
Speaker 4:Absolutely. The rating scheme is really key within CQC inspection or assessment as they're now calling inspections. Essentially, at the top of the tree, you have outstanding. Outstanding really is a real challenge actually to achieve. It's a very, very high standard and if care providers are demonstrating that they're outstanding, you can be assured that they are not only compliant but they're really exceeding standards across the board in all key areas within their provision. Good is the rating that everyone's aiming for and I think you know again, if you get a good rating, it demonstrates that you're meeting all the regulatory requirements and you're delivering good care. So you're compliant and you're delivering good care.
Speaker 4:Requires improvement is the rating that sits below good and that will tend to be where there are some bits missing. Essentially, so provider will have been found to be non-compliant in some areas. It doesn't necessarily mean that the provider is a bad provider or that they're providing bad care. Necessarily it could be reflective of that, but it could provider. Or that they're providing bad care. Necessarily it could be reflective of that, but it could be reflective that they've missed something. They've missed a key bit of evidence in terms of their compliance and then inadequate Inadequate is the lowest rating and it is a real cause for concern if a provider's rated as inadequate because it shows that they're not meeting the regulatory requirements and they're not providing care of a sufficiently high standard, and those ratings can really impact people's businesses in a range of ways, including commercially and legally.
Speaker 4:One of the things we do at Fulcrum is we analyse the rating results each month. So in the earlier part of 2024, when the single assessment framework first came in, we did see quite a high number of providers failing to get good or above, and that was quite an alarming trend really. Cqc did rectify that fairly quickly and now the results are sort of evening out at around 2% for outstanding. Sometimes it dips below that, sometimes it's above that. Good ratings tend to be around the sort of mid-55% to 58% of inspections. It requires improvement ratings a hover around the sort of 32% to 38%, and inadequate ratings are anything between sort of 4% and 7% at the moment, which is a bit of a concern that so many homes are coming out within an adequate rating. But I think those stats just kind of help to reinforce what I was saying in terms of how challenging it is to get outstanding. It really is the sort of creme de la creme of services that are achieving that rating.
Speaker 2:Yeah, I mean it's an interesting statistic there, really, with the percentages. I mean what would these ratings mean within the insurance world? Sabrina.
Speaker 3:So the CQC ratings are highly significant in the insurance world for the care sector.
Speaker 3:Basically, insurers view CQC ratings as their risk indicators and they're a key measure for the risk associated with insuring a care provider.
Speaker 3:So ultimately, the higher your rating, so a good or an outstanding generally indicates a lower risk, therefore lower premiums, broader coverage options and more favourable terms from the insurers due to a minimal perceived risk, whereas lower ratings, such as requires improvement or inadequate, suggests higher risk of claims or liabilities, generally operational and financial stability.
Speaker 3:Insurers see higher rated providers as more likely to have strong risk management practices in place, well-trained staff and a history of compliance, all reducing the likelihood of incidents or regulatory breaches, and in place well-trained staff and a history of compliance, all reducing the likelihood of incidents or regulatory breaches, and, in comparison, requires improvement or inadequate generally increases your insurance premiums because you're perceived as a higher risk, reflecting the likelihood of increased claims or incidents. And unfortunately, this does tend to give rise to limited comprehensive coverage options, possible exclusions or endorsements on your policy and even, in rare circumstances, refusal of insurance renewals if the risks are deemed too high. So this highlights the importance of having strong relationships with an insurance broker with expertise in health and care to help you navigate the complex world of social care.
Speaker 2:Okay, well, thank you for that. I mean, given that the ratings affect the insurance, I mean, how do the care businesses improve and how do the CQC respond to, you know, re-inspecting or improvements that they try to make?
Speaker 4:I think it's a real challenge for providers at the moment because the CQC are having some real, real difficulties. The regulator is facing some real challenges and some would argue is not currently fit for purpose, and what that means is that providers can be sat on an old rating for a long time and it's quite difficult to get CQC to come back out to reassess as well. So I think, from that perspective, it's really really key that providers are ready for their inspection, that they're prepared and that they make sure they are compliant and that they are going to get a good rating, because if they don't, there is a significant likelihood that they're going to be sat on a rating for a considerable amount of time because of the lack of resource within CQC to carry out enough inspections.
Speaker 2:Well, sabrina, I mean you mentioned obviously some of the potentially lower ratings that are given can affect in many negative ways, but what can people do to reassure, for example, underwriters that the services have improved? Is there anything else that they can be doing to reassure the insurers whilst the inspections haven't taken place? The reinspections?
Speaker 3:Yeah, I mean it's always really important for a provider to be able to show that they are making those improvements while waiting for a CQC reinspection steps, basically to reassure their stakeholders, including service users, families, staff and ultimately the insurance underwriters. Ways of doing that would be sort of document sharing, sharing evidence that you have undertaken improvements. A lot of providers that are rated maybe requires improvement or inadequate will then need an improvement action plan that can be shared with the CQC or your local authority and especially your underwriters, to show that actually you have got risk management in place and you are actively looking to improve your business and to take those steps to show that actually you are commercially viable and you are safe and effective.
Speaker 2:Well, I mean, how big of an issue is this and is it affecting many care providers?
Speaker 4:if we start with yourself, Becky, I think it is a big issue actually, and I think something that happened earlier this year was that the CQC brought in a new way of inspecting which is called the Single Assessment Framework, and it changed the regs.
Speaker 4:Haven't changed the regulations the underpinning regulations are the same but actually the way they come in and assess compliance against those regulations has changed quite significantly and I think some providers have been a bit caught out by that and so essentially especially because people haven't been inspected for a long time as well that, coupled with a new way of inspecting, I think has left some providers in a situation where they haven't got the rating they wanted and they're perhaps ending up with an RI, when you know actually previously they've been good, they've been used to being good. They're maybe sort of lulled into a little bit of a false sense of security and that does have an impact on their business. Obviously, you know it has an impact in terms of how they're viewed by, you know, potential clients, residents or service users, depending on what sort of care business it is, and also, obviously, other stakeholders, so commissioners and other stakeholders such as family and so on.
Speaker 2:And Sabrina, I mean you are currently involved in a care home. How would you say the feeling is in the care owners' community about the CQC right now, the new frameworks that have been mentioned by Becky?
Speaker 3:I think that there's a lot of mixed feelings out there. I think that, as a provider as Becky mentioned when the single assessment framework came in, it caused a lot of sort of upset because people had, as you said, been sitting on a rating for a long time and actually a single assessment framework. If you're being re-inspected on that framework, it proved quite difficult for some providers. But I think we have to also understand it is what it is. The single assessment framework is in place and that's what that's how we're.
Speaker 3:You know care providers are being assessed, but I think that ultimately, if there needs to be, I think education is really important actually understanding how the single assessment framework works and how to basically showcase yourself and show that evidence under each quality statement to really show how you're making those improvements and the things that are in place already are working. I think that's a really good thing to do and also by doing that, you're not only just showing the CQC that you know you're trying to improve your service, but I think it has far wider impact. You know things like potential new service users coming in. Local authorities will look at you more favourably. Even staff you know people that are working in care homes are more likely to be attracted to a provider that is sitting on a better rating than one that's not so strong.
Speaker 2:And I mean, is there an issue amongst the sort of electronic versus paper records with the CQC? Because we're hearing that everyone's trying to go digital but some people maybe aren't caught up with it or, you know, is there a bias against that? What's what's happening there?
Speaker 4:I think there is a real push for people to to move to electronic care management and I and I and I think you know I'm a real advocate for it. It it gives providers a huge number of benefits and a much, much better visibility of what's happening in their services. So I'd certainly advocate for it. I think we sort of see a mixture, and so we do still see some smaller providers that are using paper records and, interestingly, we also sometimes see a dual system happening where which can be a risk in itself actually but where people have got electronic records but then they're still doing some things on paper. So we see a mixture, I think. From a CQC perspective. I think they like systems, they like the data and the information that comes out of systems. But you still can be compliant with paper. You just have to make sure that you've got that visibility. You have to make sure that you've got that visibility. You have to make sure that you have oversight, and that's a lot harder to do on paper than it is on a system. Yeah, completely agree.
Speaker 2:Wonderful. I mean, with all we've discussed today, what, between the two of you, do you think are the key things a care business can do to prepare for a new inspection? Now, I understand that the majority of them are likely to be unannounced, but are there things that they can do to fully prepare for the next time the CQC officer walks through their doors?
Speaker 3:If we start with yourself, sabrina, Sure, I think it's always really difficult to prepare for an unannounced CQC inspection, but I think, first and foremost, it's really essential to consider everything that came up in your last inspection and look to foster a culture of basically continuous improvement on that.
Speaker 3:I think that things like the obvious things, potentially like making sure that you're up to date in all of your policies and procedures, everything that is in your policies and procedures is being embedded actually in your working practices, because it's great having lovely, you know well-written policies and procedures. I think that, ultimately, if they're not being carried out in day-to-day practices, then that's something that will likely be shown in an unannounced inspection. Also, things that can be done, such as regular audits at management level to make sure that everything is being followed in terms of procedures. It's also useful to consider mock inspections and things like that so it can identify areas of where you might be potentially falling down, so that you can again go back to the continuous improvement and also focus on your staff and training. I think that's really important. Ultimately, again, they're the ones that are doing the day-to-day caring and management of service users, looking after service users. So if they're well-trained, understand their roles and are in a good culture and environment, then they're very likely to really improve your environment of your home.
Speaker 2:Wonderful and Becky. If I can put it to you as well, Same question.
Speaker 4:Yeah, absolutely. I think Sabrina's made so many good points I'm going to have to try and think of some more. No, I think from my perspective, it's being prepared is really really the key thing. So all providers have to complete a document called the Provider Information Return PIR. That is your first opportunity to start showcasing what's good about your service and how you meet the quality statements. So that's sort of step one. Step two is making sure that you've embedded the quality statements into your day-to-day practices.
Speaker 4:It's really important that your staff understand them, your team understands them, that they know what they are and that they also know how they're going to evidence that they're meeting them. So it's literally having those as part of your culture, part of your day-to-day ensuring that the staff understand what the evidence looks like, because what's really important is that when the CQC inspector arrives, that you're giving them all the evidence that they need to be able to say, yeah, actually this provider is meeting the requirements and get that all-important good rating. What CQC do now is they really triangulate the evidence in a bit more of an in-depth way, I would say, than perhaps the previous way of inspecting. So they'll, they will look at a specific area. They'll then sort of follow the thread of evidence, say they'll talk to your staff, they'll talk to your residents, they'll look at your paperwork, they'll look at your policies and procedures, check that they're embedded, check that the right training's been done, and so it's.
Speaker 4:It's about providers making sure they can really evidence that, and what we do see sometimes is providers doing some brilliant stuff but it's not been documented. So if it's not been documented, it hasn't happened. So I think that's really important. It's making sure everything's documented, you've got all your evidence ready and that you can demonstrate. You've got an overarching governance structure in place which is around Reg 17.
Speaker 4:So you might want to, as Serena said, you want to be able to show that you're doing regular audits, that you're having, for example, potentially mock inspections from someone external like ourselves, um. But if you're not doing that, that you are doing those checks internally, that you're recording it, that you can evidence it and that you can show that you're doing that on a regular basis and that you're using that information to then improve your service. So, yeah, I think it's always scary when CQC turns up. So being prepared is really important, and also showcasing your service to the inspector and and sort of giving your staff that confidence actually in what they're doing, so that, yeah, the heart rate always goes up when CQC arrive and that's completely understandable.
Speaker 3:But you can impact the outcome by being confident, by having the evidence there to show them and and really sort of showcasing your service and how you meet each quality statement definitely and, on a practical note, I think it's really important to make sure that when the inspector does arrive at your door, that everyone's prepared and meeting them warmly, because I think that's the the other thing.
Speaker 3:Everyone sort of you know, dreads the CQC inspector sort of knocking on the door, but ultimately, we're all doing a role and everyone's doing it well generally. I think it's just a case of being able to, to show that, to evidence it, and and I think that it all starts with the meeting at the door, doesn't it? I think it sort of sets the tone. One of the things that I've heard of recently, actually, is I've heard of a particular service. They give a welcome pack to the inspector and in that it includes key documents such as your statement of purpose, your policies, any audit outcomes and even an improvement plan. So straight away, you know, you're setting the tone for that, for that conversation and for that inspection, which I think is a really good idea yeah, definitely, definitely.
Speaker 2:It sounds from what you're both saying. It's obviously preparation is key, but then also being confident in the preparation that you've done to, as you put it, showcase what you do. So sounds very good In terms of an insurance point of view, sabrina, what are the fundamental aspects of insurance that the CQC require?
Speaker 3:Okay. So, in terms of CQC requirements, employers Li liability insurance. It's a legal obligation in the UK for care providers to hold employers liability insurance. I think the minimum coverage is 5 million and obviously the purposes of that is to protect the business against any claims made by its employees for things like workplace injuries or illnesses during employment.
Speaker 3:The other insurances that care homes and providers should consider is public liability insurance. Although it's not mandatory, it's really considered essential for care providers. The purpose of that is obviously to cover claims such as those made from third parties visitors, contractors or even service users, families for injuries or property damage occurring on the premises, and then things like med mal medical malpractice insurance. The requirement for that is specific to care providers offering medical services, such as medical administration or clinical treatment, so it's not always something that all care providers need, but that covers claims and things related to injury, illness, death caused by medical negligence, and then just the general building contents insurance, really to protect the premises and contents for delivering the care services, so really important. The other things to consider are always cyber liability insurance, which is just coming up more and more now, isn't it In terms of the move to everything being online, and so yeah, that's really important as well so I mean, I think we've covered a lot of the bases.
Speaker 2:If I could just ask for your final thoughts, both of you, if we start with yourself, becky, your final thoughts on the cqc, where we are today and uh, yeah, what, what people can do moving forwards yeah, yeah, I think there's.
Speaker 4:Obviously there has been some real challenges for providers as a result of the difficulties that CQC faces as an organisation. Cqc has a new CEO and I think they're looking at bringing in chief inspectors for each key area, which I think will really help. They're kind of going full, full circle back to sort of some of the things they were doing but doing sort of prior. They're also piloting a new relationship based approach and they're reviewing the single assessment framework to try and refine that as well. So I think where we are now, you know, providers have got to be prepared and they've got to be ready for the new way of inspecting. But also, I think, watch this space in terms of changes incoming, and I, for one, am quite hopeful that there will be some positive changes. I think it's going to take some time for it to happen and for them to be embedded. So providers have just got to keep abreast of what's happening with the regulator and make sure they're prepared.
Speaker 2:And Sabrina.
Speaker 3:Yeah, just to basically agree with what Becky's raised. I think it's just really important for providers to, as Becky said, keep abreast of what's going on out there. What's going on out there. I think it's really actually quite easy to fall into a bit of a trap after COVID etc. Of not always being up to date with the changes, and I think that that can cause some difficulty sometimes. But ultimately, I'm in agreement with Becky. I'd like to say that things are improving. It will take time. It's such an important sector to ensure that those in care are receiving the best care that they can receive, but it's also coupled with making sure that we are following the relevant regulations in place as well.
Speaker 2:Brilliant. Well, look, I think this has been eye-opening, very informative and interesting, but unfortunately we're gonna have to stop it there. That's all we've got time for today. I'd like to thank you both. Thank you, becky, thank you, sabrina, for joining us. Is there anywhere that people can find you on, either linkedin or where, potentially, they can get further information if required?
Speaker 4:yeah, absolutely. You can find me on on linkedin and also fulcrum care on linkedin as well, and our website too.
Speaker 3:So yeah and same with me. I'm on linkedin and on the website howdenbrokingcom wonderful.
Speaker 2:Well, thank you ever so much, and thank you to all of our listeners today, until next time thank you for listening to this episode of fortune favors the brave from howden.
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