External Quality Regulation
Last Updated 17 June 2022
Recommendation 3 of Sir Jonathan Michael’s Independent Review of the Isle of Man Health and Social Care Systemcalled for health and social care services provided directly or indirectly by Manx Care to be inspected regularly by independent, external quality regulators, with a report to the Manx Care Board and to the Department of Health and Social Care (DHSC). It was also recommended that the inspections are determined against agreed defined standards that provide assurance yet require the enforcement of the recommendations and support a systematic approach to a continuous improvement.
The External Quality Regulation project was established within the Health and Care Transformation Programme to support the Department of Health and Social Care who will ensure that there is a consistent, independent and systematic approach to the inspection of all health and care services delivered or commissioned by Manx Care.
Work to date
Following the recommendation, the Care Quality Commission (CQC) in England was identified as being able to assist recommendation 3 and conduct initial baseline inspections of the majority of services in adult social care (ASC), primary medical services (PMS) (including GPs, dental care, minor injuries and out of hours) and the hospitals. DHSC commissioned CQC to carry out these baseline inspections, a service level agreement (SLA) was signed in July 2021 to conduct this work and Phase 1, the validation phase was concluded in November 2021. During Phase 1, CQC staff and specialist advisors held a series of workshops and on-Island meetings with management across Manx Care, DHSC and several of Manx Care's contractors.
This has aided all organisations involved to better understand what and when engagement is required and how CQC will apply its current inspection approach to the nuances and challenges of the provision of Health and Care on the Isle of Man.
The initial scoping exercise has now taken place, mapping out a bespoke end-to-end process that would best fit services on the Isle of Man. The result of that work established the current intention to send each provider and location a report containing a baseline assessment, which does not contain any ratings. CQC has not been given enforcement powers as part of this work.
The Adult Social Care, dental and GP frameworks have been shared with the DHSC, and the ASC and dental have been approved. The GP framework will be finalised following on from the pilot and the CQC consultations with the local providers on the content were successful, which concluded Phase 2 of the process.
Phase 3 is now underway as inspections of ASC services commenced at the end of April and are scheduled to run until August, with CQC inspectors visiting the island regularly to review services according to the program.
Question and Answer sessions for the GP and dental services were held during May to allow practices the ability to communicate directly with CQC and DHSC regarding their pending inspections. A pilot inspection of the urgent and emergency care department of Nobles’s Hospital will take place in mid-June.
Inspections of Dental and GP services are due to commence at the start of July and be concluded by the end of September. For full details of inspection schedule, see “Phase 3” section below.
Who are the Care Quality Commission?
The Care Quality Commission register, inspect and regulate health and social care services in England. Their expertise in regulation and inspection to support the recommendation when approached, made them the best placed organisation to undertake a baseline inspection of services provided and/or commissioned by Manx Care and furthermore support the development of an ongoing approach to independent external quality inspections.
What is the timeline for inspection activity?
The work on the Isle of Man is being undertaken in three phases.
Details of the three phases can be found below.
Phase 1: Initial validation and scoping exercise (July – November 2021)
This phase has involved workshops to map the end to end methodology for delivering inspections across the Island and focused primarily on service-wide and location-level baseline assessments with a report and no ratings.
Phase 2: Discovery and self-assessment (December 2021 – March 2022)
The assessment framework will be adapted in co-production with organisations to help them understand what intelligence is available, how they can hear about people’s experiences of care, and how they can understand the quality of care being delivered by services, from services.
Engagement work with services has commenced in connection with the Provider Information Requests (PIR).
The DHSC in conjunction with CQC will consult on the framework by:
- learning what data is available,
- managing pre-assessment information requests,
- delivering webinars,
- undertaking some pilot inspection work.
Phase 3: The inspection phase (April – October 2022).
This will be the inspection phase where CQC will undertake a baseline assessment of the services commissioned and provided by Manx Care on behalf of IOMDHSC.
The current timeframes (correct at 17 June and subject to change) are:
- The Adult Social Care inspection schedule will run from 25th April to 12th August 2022.
- 9 x Adult Care Home
- 27 x LD Adult Care Home
- 7 x Other Social Care Service
- The Dental inspection schedule will run from 4th July to 15th July.
- 13 x Dental Practices
- The General Practice inspection schedule will run from 26th July to 21st September
- 13 x GP Practices
- The Mental Health Sector inspection will begin 1st August.
- The Hospice Sector inspection will begin week commencing 19th September.
- The Hospital and Community Services Sector inspection schedule will begin on the 3rd October, following a pilot inspection of the Urgent and Emergency care Department from 13th to 15th June.
This means that some of the engagement with management and staff in the hospitals will also start at a later date.
DHSC are working across Manx Care to co-develop the assessment frameworks and establish the necessary guidance, so that all services who are being inspected know what to expect and feel supported and confident in the process, as well as understanding its purpose.
What services will be inspected and why?
All services provided directly and indirectly by Manx Care are to be inspected. Although CQC are able to inspect the majority of these services, there are a small number not ordinarily regulated by CQC in England and therefore out of their scope. These include day services for learning disability and older people, community ophthalmic, community pharmacy and some children and family services. Investigation work is now underway with other regulators to determine whether they are able to inspect those services that currently sit outside of the scope of CQC.
Private services that do not receive Manx Care funding will not be inspected by the CQC during these initial baseline inspections. However, if they are registered under Regulation of Care Act 2013 (ROCA) they will be inspected as usual by the IOMDHSC Registration and Inspection unit. Further discussions are already underway to look into ways to include independent services in the approach for the future.