Reforming the CQC

Tracey Jones shares insights into Dr Penny Dash’s review and the challenges of regulatory change

TRACEY JONES

Tracey Jones began her career in 1996, training as a nurse and dedicating much of her professional life to neonatal intensive care. She later advanced to the role of clinical matron, overseeing four major departments. For the past two decades, Jones has transitioned into academia, f irst as a teaching fellow and then as a senior lecturer at a world-renowned university. In this capacity, she has presented at numerous UK and international conferences and has been widely published, including the release of her own academic book in 2020. Jones is also a senior fellow of the Higher Education Academy and has contributed to the development of educational modules for NHS England and the World Health Organization. For over 10 years, she has served as a clinical specialist advisor to the CQC and runs her own CQC-registered clinic, Blend Skin, in Cheshire, which she co-owns with her daughter, who is also a nurse.

In early 2024, Dr Penny Dash was commissioned to conduct a comprehensive review of the Care Quality Commission (CQC), the body responsible for regulating health and social care services in England. Later that year, the findings of her published review presented a stark and uncomfortable reality for the CQC, exposing critical limitations in its internal operations, the effectiveness of its assessment processes, and the capacity of the organisation to meet the demands of a rapidly evolving healthcare landscape.

Dr Dash’s review involved consultations with over 300 senior managers, clinicians, caregivers, and patients, in addition to staff working within the CQC itself. Her findings were alarming, with nearly all the individuals interviewed expressing significant concerns about the working practices and efficiency of the CQC. Many of these concerns were raised in the context of the CQC’s ongoing efforts to integrate a new provider portal, a system which, despite its ambitious goals, proved to be deeply difficult to use. Additionally, providers raised concerns about the Single Assessment Framework (SAF), the CQC’s regulatory platform, and its organisational structure all of which had been previously flagged by CQC staff themselves. These findings painted a picture of an organisation struggling to modernise and align with the evolving needs of both service providers and the public.

The need for an effective healthcare regulator, however, remains unquestionable. The CQC, like its counterparts in other devolved nations, plays a vital role in ensuring the quality and safety of healthcare services. However, as Dr Dash’s review highlights, even well-intentioned regulatory bodies can face significant operational challenges that can then undermine their credibility.

THE CQC TRANSFORMATION PROGRAMME

In 2021, the CQC embarked on an ambitious transformation programme to modernise its approach to regulating health and social care services. The core objective of the programme was to make the assessment and inspection process more straightforward and data-informed, reducing unnecessary complexity and improving consistency. A key element of this transformation was the introduction of updated IT systems, a restructuring of operational inspection teams, and the rollout of a new regulatory model known as the Single Assessment Framework (SAF). For providers like me, particularly in medical aesthetics, these changes were viewed as a positive step forward. The introduction of a more transparent scoring system for inspections, based on clear evidence requirements, seemed to offer both greater clarity and a fairer system of rating. Under the SAF, inspectors are now required to justify their ratings using a scoring matrix, providing registered managers with guidance on improving and offering more transparency in how ratings are awarded. From a provider perspective, this scoring system represented a significant shift towards a more objective and evidence-based evaluation, which could be beneficial both for quality improvement and for understanding how to achieve higher ratings.

However, Dr Dash’s review revealed that, despite the CQC’s best efforts, these reforms have not been without their challenges. Internal failings have led to a loss of credibility of the CQC. The report found that the CQC’s capacity to identify poor performance, drive improvements, and support providers effectively had significantly deteriorated. In my own experience as a director of a regulation consultancy company, I observed the consequences of these systemic failures firsthand. Applications that once took approximately 12 weeks to process were now taking as long as 12 months, resulting in significant personal, emotional, and financial strain on clients who were desperately waiting for their CQC registration to launch new businesses. This delay was exacerbated by the inefficiencies of the CQC’s provider portal, which only added to the frustration of providers navigating an already complex regulatory environment.

In response to widespread feedback and a series of internal reviews, the CQC decided to close its existing application portal on November 18, 2024. The portal, which was designed to streamline the application process, was instead a source of frustration for many providers. Delays, misplaced applications, and difficulties navigating the system caused undue stress for those seeking to register or update their services with the CQC. As a result, the CQC has reverted to a manual process, requiring service providers to submit their applications and supporting evidence via forms available on the CQC website.

As of last November, all new applications or updates to existing registrations need to be submitted through the new manual process. The evidence required to support quality statements remains part of the application process, but it now needs to be integrated into the Statement of Purpose. While this shift is intended to create a more user-friendly system and reduce backlogs, it marks a significant step back from the CQC’s initial attempts to modernise and simplify its application process. The portal, which had been promised as a key part of the CQC’s plan to improve efficiency and reduce the administrative burden on both providers and the regulator, has instead failed to deliver. Some applications, including those for clients I have worked with, have taken up to 12 months to process, far from the CQC’s goal of reducing response times and improving transparency.

THE NEED FOR A BALANCED REGULATORY APPROACH

The closure of the portal represents a critical turning point for the CQC, as it acknowledges that its efforts to modernise the regulatory process have not met expectations. The move back to manual forms may seem like a regression, but it also highlights the need for a more thoughtful and balanced approach to healthcare regulation. While technology and automation are essential in streamlining processes, they must be implemented in a way that is reliable, efficient, and accessible to the people who depend on them. Moreover, the issues identified in Dr Dash’s report raise important questions about the future direction of how the CQC will regulate health and social care providers. This is the pinnacle of aesthetic medicine which will undoubtedly cause an increased workload for the CQC if the anticipated changes in regulation come to fruition. The challenges outlined in the review offer an opportunity for the CQC to reflect on its approach and to make meaningful changes that will ultimately benefit both service providers and the patients they serve. In my view, I do not see the CQC’s purpose to solely enforce penalties, I see the regulatory body as a partner in care, an organisation that is invested in improving quality healthcare outcomes. A true “critical friend” is someone who offers constructive feedback and guidance, helping providers like me identify areas of improvement and providing actionable steps to enhance the services I offer. In my experience, CQC inspections can be a valuable opportunity for growth. When a clinic team engage with regulation this can drive a collaborative and solution-oriented approach, fostering a culture of continuous improvement.

As the sector continues to evolve, so too must the regulators. The goal should be to create a regulatory environment that is transparent, fair, and conducive to ongoing improvement, one that strikes a balance between oversight and support. For healthcare providers like myself, and those seeking to navigate the regulatory landscape, this balance will be key to ensuring that the CQC fulfils its mission of promoting safe, high-quality care for all. The closure of the CQC’s portal and the return to manual applications marks the beginning of a new chapter in the ongoing evolution of healthcare regulation in England. It remains to be seen whether this shift will provide the clarity, efficiency, and support that service providers need to thrive in an increasingly complex healthcare environment.

As a nurse, regulation consultant, and the owner of a CQCregistered clinic, I have a unique vantage point when it comes to the role of healthcare regulators in aesthetic medicine. My expectation of the CQC, and any regulatory body, is simple; I want them to not only understand my service but also serve as a critical friend in helping to identify areas for improvement, ultimately ensuring that my patients receive the best possible care. The field of aesthetic medicine is undergoing significant changes. The demand for non-surgical cosmetic treatments continues to rise, and with that comes increased scrutiny and the need for clearer regulatory frameworks. As we await further guidance on the proposed licensing scheme for aesthetic practitioners, regulation remains in a state of flux. Despite the uncertainty, one thing remains clear: I will continue to maintain my CQC registration. For me, being registered with the CQC represents the pinnacle of assurance for my patients, a commitment to high standards of care and a mark of quality that instils confidence in those seeking services at my clinic.

WAITING FOR NEW GUIDANCE: A PERIOD OF TRANSITION

Aesthetic medicine is in a period of transition. The proposed new licensing schemes for non-surgical aesthetic procedures are aimed at raising standards and providing clearer accountability across the industry. While many of us await the publication of these new guidelines, we understand the need for regulation that better reflects the complexity of the medical services we provide. These reforms aim to create a safer environment for patients and ensure that medical aesthetic treatments are carried out in the highest standard of care by medical professionals.

The CQC’s registration process is not merely about compliance; it is a holistic evaluation of every aspect of a service, from governance, patient care and safety protocols. In an industry where there is currently no licensing framework and some practitioners jeopardise both their medical registration and credibility by offering services while being unregistered with the CQC, practices may not always adhere to the highest standards. CQC registration offers a crucial layer of reassurance for patients who might otherwise feel uncertain about where to seek their treatment.

As we await further clarification on the licensing of non-surgical cosmetic procedures, all practitioners in this field need to remain engaged with regulatory bodies like the CQC. The landscape is shifting, but the goal remains the same – to ensure that patients receive the highest standards of care. By continuing to embrace regulation, I believe we in the specialty of aesthetic medicine can help drive the changes necessary to raise standards and build a more professional, safe, and transparent industry.

As a nurse, I am proud to work within a regulatory framework that helps ensure my patients receive the best possible care, and I will continue to support efforts that raise the standard of care across the entire sector. In conclusion, while the world of aesthetic medicine is rapidly evolving, my commitment to patient safety and quality care remains unwavering. Staying CQC registered is an essential part of this commitment, and I believe that, through collaboration with regulators, we can ensure that this sector continues to grow in a safe, regulated, and patient-focused direction. The path forward may be uncertain, but by embracing regulation and remaining open to continuous improvement, we can provide the best possible care to those who entrust us with their health and well-being.

The challenges identified in Dr Dash’s review reflect the complex nature of healthcare regulation and the need for constant adaptation. As the CQC looks to address its shortcomings and rebuild its credibility, any future reforms must prioritise both efficiency and fairness to serve as a robust and supportive regulatory body for the health and social care sectors.