Did you know that CQC have been making improvements to the Provider Information Return (PIR) for a while now and as of the 7th August 2019 they have been asking Providers to complete the updated version?
CQC use the Provider Information Return to monitor the quality of care that is provided by a service. They request information about a service every year so that they are informed about any changes that have been made by the service and how the Provider makes sure that the service is safe, effective, caring, responsive and well-led.
CQC have said that they will ask questions about people who use the service; about the staff team; and the way that the service is run.
They will ask about:
• admissions and new people who use the service
• drugs and medicines management
• nutrition and hydration
• who commissions care from the service
• how the service works with other services and professionals
• staff training and supervision
• the Registered Manager
• awards that have been won or initiatives that the service is involved in that helps to show the quality of care that is provided
• how the service applies the Mental Capacity Act 2005
The basic information is what Providers have completed in their previous PIR’s and should be readily available to both the Provider and Manager. The major change is when CQC request a PIR.
CQC used to request a PIR from a Provider around the time that they were going to undertake a comprehensive inspection visit. This has now changed and CQC will request a PIR during the anniversary month of your first site visit and then on an annual basis thereafter. This will enable services to be prepared and plan for completing their PIR.
Services will know when their PIR is due and so failure to complete and return it in the timescale stated (28 days) will not be tolerated by CQC and the Provider will have no legally legitimate excuse for failing to meet the deadline.
CQC have stated that they will be writing to all Providers, to inform them of the changes and details of the updated questions and guidance; and to remind them of the date of their first site visit. After all, some services may not have this information to hand.
Provider Information Returns need be returned to CQC within four weeks of receiving them.
By letting services know what month they should expect their PIR, CQC have tightened their ability to enforce the legislation. Regulation 17(3) – Good Governance of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 states that
17(3) The registered person must send to the Commission, when requested to do so and by no later than 28 days beginning on the day after receipt of the request
(a) a written report setting out how, and the extent to which, in the opinion of the registered person, the requirements of paragraph (2)(a) and (b) are being complied with.
Paragraphs (2)(a) and (b) relates to systems and processes that the service has to assess, monitor, and where required, improve the quality and safety of services of their services.
As you can see, the regulation sets out the need to complete the PIR and also sets the timeframe for completion of it to 28 days. Failure to submit the PIR or meet the deadline for completion means that the highest rating that they will award for the ‘well-led’ key question is ‘requires improvement’. This will result in a breach of Regulation 17(3). CQC can also prosecute directly for a breach of this part of the regulation without having to first serve a warning notice.
So, Providers will be aware of when their PIR will be due on an annual basis and should be preparing for it in advance. After all, the information that CQC are requesting should be what services have been compiling as part of their ‘good governance’ or Regulation 17 processes and audits.
The PIR request will no longer be indicative that an inspection is due in the near future, meaning that the inspection process will have a greater unannounced feeling to services and they will not be able to ‘prepare’ for an imminent inspection as some services have in the past. In turn, this will help to drive and improve quality for people who use the service as an inspection can be due at any time.
The PIR will also be used by CQC, as well as other intelligence that they receive to determine when the next inspection will be. Services that are rated as ‘good’ or ‘outstanding’ will normally have a comprehensive inspection within 30 months of the last comprehensive inspection report being published.
Services rated as ‘requires improvement’ will normally have an inspection within 12 months; and services rated as ‘inadequate’ will normally be inspected within 6 months of the last comprehensive report being published. These are the maximum time frames that CQC work to in their inspection planning. Services that are rated ‘requires improvement’ overall but have one key question rated as ‘inadequate’ CQC plan on inspecting those services within six months.
Let us see what sort of an impact these recent changes will have on the ratings of health and social care services going forward.
Care Home Support and Training are here to help services develop their processes and strategies and to help them to drive and sustain quality improvements. If you have any queries or what to know how Care Home Support and Training can help your service, please do not hesitate to contact us. We are different from other care consultancies and focus on working with Managers and Providers to offer service-centred, affordable solutions. Find out how we can help your service today.