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  • Patient Safety Learning: Reflections on the CQC’s new strategy (15 March 2021)

    Summary

    In this blog, Patient Safety Learning outlines the key points included in its response to the Care Quality Commission’s (CQC) consultation on their new strategy from 2021, identifying the opportunities this presents for the health and social care regulator to help improve patient safety.

    Content

    In January the CQC published a formal consultation on its new strategy from 2021.[1] The future aims and ambitions of England’s health and social care regulator clearly have important implications for improving patient safety. It not only plays a key role in assessing and holding organisations to account on safety issues, but also has the influence and reach to promote and spread patient safety improvements and good practice more broadly at a system level.

    Here we will briefly overview the aims and ambitions of the CQC’s new strategy, before then reflecting on the key points we included in our consultation response around the following issues:

    •  Patient engagement.
    • Transparent patient safety data and insight.
    • Tackling the blame culture.
    • Driving improvement and sharing learning.
    • Human rights.
    • Standards for patient safety.

    “The world of health and social care is changing. So are we.”

    The CQC is the independent regulator of health and social care in England. They describe their purpose as:

    We make sure health and social care services provide people with safe, effective, compassionate, high-quality care and we encourage care services to improve.”[2]

    The key ambition in their new strategy reflects this purpose, with their aim being “to improve people’s care by looking at how well health and care systems are working and how they’re acting to reduce inequalities”.[1] The strategy is built around four themes which group together the changes they believe will help to achieve this:

    1.    People and communities – regulation to be driven by people’s experiences and what they expect and need from health and care services.

    2.    Smarter regulation – flexible and dynamic assessment processes, targeted and driven by data.

    3.    Safety through learning – focus on strong safety cultures and the importance of learning and improvement.

    4.    Accelerating improvement – commitment to making improvement happen and targeting the priority areas that require the most support.

    In the following sections of this blog, we will reflect on some of the key issues included in our consultation response on this strategy, identifying the opportunities this presents to help improve patient safety.

    Patient engagement

    We welcome the new strategy identifying the importance of people’s experiences of health and care services as an having an integral role in the CQC’s work. Patient Safety Learning believes that engaging with patients is key to improving patient safety. Too often, safety concerns raised by patients and family members are not acted on and, when harm occurs, they are left out of the investigation process.

    We were pleased to see the strategy commit to:

    • Simplifying the CQC’s feedback processes for the public.
    • Providing clear feedback on how people’s experiences have been used and indicating where these have resulted in action.
    • Assessing health and care providers on how they enable and act on feedback.

    As part of our consultation response we also underlined the need of CQC’s assessment of health and care providers on patient feedback to be joined up with the Parliamentary and Health Service Ombudsman (PHSO) work forming a new Complaint Standards Framework for the NHS.[3] As we noted in our response to the PHSO’s consultation on the latter, it is vital the two organisations work in this area is aligned and mutually reinforcing.

    In addition to individual engagement with patients, in our response we urged the CQC to give further thought to how they engage with patient groups and campaigners. Last year’s major patient safety report of the Independent Medicines and Medical Devices Safety Review (also known as the Cumberlege Review) clearly demonstrated the vital role that patient groups can play in highlighting systemic safety failings.[4] At Patient Safety Learning we are currently working closely with patient groups to highlight patient safety concerns impacting people living with Long Covid and women who have experienced painful hysteroscopy procedures in the NHS. We believe there is a significant opportunity for insights from such groups to help inform the CQC’s approach to regulation and inspection.

    Transparent patient safety data and insight

    Another key theme of the new strategy is smart regulation, emphasising the use of data to target CQC resources where they can have the greatest impact. In our response we noted that if these ambitions are to be realised, there needs to be a significant improvement the available metrics and data, particularly in relation to patient safety.

    In our report A Blueprint for Action we identify data and insight as one of the six foundations of safe care.[5] We set out the importance that health and care providers to have agreed metrics and data to manage and measure their patient safety performance. We believe that this should be integrated from different sources of patient safety intelligence and learning, subsequently utilised to identify possible patient safety risks, and inform decision making throughout the organisation. Access to more rigorous, effective, and transparent reporting is key to the CQC becoming a smarter regulator on patient safety issues.

    Tackling the blame culture

    We were pleased to see “Safety through learning” as one of the four core themes of the new CQC strategy. An organisational culture that seeks to assign blame when things go wrong makes patient harm more likely to happen again. Blame culture incentivises people to cover up mistakes, rather than reporting them, and often singles out individuals rather than tackling the systemic causes of errors.

    Sadly, we know blame cultures continue to persist in the NHS. Evidence of this can be seen the results of the most recent NHS Staff Survey, with an alarmingly high number of respondents (39.1%) indicating they did not feel staff involved in an error, near miss or incident would be treated fairly.[6] We also see signs of this reflected through conversations with staff via the hub, with a reluctance to share examples of good practice as well as concerns about unsafe care. Staff express their commitment to share insights, stories, data but also their fear that they will be ‘found out’ and do not have permission even to share good practice. Therefore, we welcome the strategy’s focus on this in our response, particularly commitments to:

    • Its assessments checking for open and honest cultures.
    • Sharing learning from good safety cultures.
    • Ensuring services are investing in improving safety training and support.

    Driving improvement and sharing learning

    As part of its “Accelerating improvement” theme, the strategy emphasises the importance of sharing new innovations and establishing “national sector-wider improvement coalitions”. We welcome this commitment to sharing learning and examples of good practice.

    Patient Safety Learning believe that shared learning is key to improving patient safety, identifying this as one of our six foundations of safe care in A Blueprint for Action.[5] We bring together resources and learning both from health and social care stakeholders, staff and patients through the hub, our platform for patient safety. In our consultation response we said we would welcome the opportunity to share our experience and collaborate with the CQC and other organisations in sharing learning to improve patient safety. We would also be happy to share improvement insights and examples of good practice on the hub.

    Human rights

    The CQC’s new strategy emphasises that reducing inequalities in health and care and advancing human rights should be a key thread running throughout all its work. At Patient Safety Learning we have recently been undertaking work looking at the interrelationship between patient safety and human rights, considering how the right to health can also be considered as a right to safe care. We believe that this is likely to become an issue of increasing importance and have said that we would be happy to feedback to the CQC our future insights on this issue. We will be publishing our work in this area shortly.

    Standards for patient safety

    To “improve people’s care by looking at how well health and care systems are working” we believe it is essential that health and care providers and the CQC can effectively assess patient safety performance. Currently this is difficult as everyday approaches to patient safety are inconsistent – there is no clear definition of what is ‘good’ looks like, there are no standards for patient safety.

    In our consultation response we set out that we are in the process of developing organisational standards for patient safety, using the evidence-based foundations in A Blueprint for Action. We believe that the introduction of patient safety standards will enable health and social care organisations to apply evidence-based criteria for evaluating, managing, and improving patient safety performance. They will be able to assist both providers and regulators in self-assessing patient safety performance on issues such as safety culture.

    With an external and independent accreditation framework, we think that Patient Safety Learning’s organisational standards for patient safety will enable patients, staff, leaders, and regulators to have greater confidence that patient safety will be a core purpose in the health and social care system. Setting standards with external accreditation, we believe, will be a significant contribution to raising performance on patient safety and reducing avoidable harm.  We are sharing and discussing our work with the CQC. We welcome CQC’s commitment to encouraging organisations to take ownership to setting and delivering patient safety standards, not just relying on CQC and other regulators to provide insights on performance.

    References

    1.    CQC. The world of health and social care is changing. So are we. 7 January 2021.

    2.    CQC. Who we are. Last Accessed 10 March 2021.

    3.    Patient Safety Learning, NHS complaints system is not working – this might fix it, says Ombudsman, Patient Satey Learning's the hub, 22 September 2020.

    4.    The Independent Medicines and Medical Devices Safety Review, First Do No Harm, 8 July 2020.

    5.    Patient Safety Learning, The Patient-Safe Future: A Blueprint for Action, 2019.

    6.    NHS Staff Survey, NHS Staff Survey 2020: National results briefing, March 2021. 

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