Talk Health and Care

Registering The Right Support

Registering the Right Support was published in June 2017 by CQC. Within the Scope and Purpose of the document, it is referred to as a ‘policy statement’. Having spoken to several colleagues, there appears to be a consensus that as the regulator, CQC is intended to act in that capacity, but not as a ‘policy maker’. Through the document the content refers to both ‘guidance’ and ‘policy’, therefore it was unclear at the point of publication how this would be interpreted and therefore implemented.

 

Whilst I am sure all providers would like to ensure that Winterbourne View is never repeated and therefore welcome changes that will reduce the risk of any harm to someone with a learning disability (or any other individual), there are many factors to consider in relation to how this will be achieved. The primary focus of Registering the Right Support relates to the size, location and type of services being offered. All well and good, but the ‘guidance’ element of the document remains very unclear and refers to CQC adopting ‘the presumption of small services, usually accommodating six or less’. However, then goes on to say that ‘we will not adopt six as a rigid rule for providers of any service for people with a learning disability and / or autism’, providing that providers ‘are able to demonstrate that they follow all of the principals and values in Building the Right Support’ guidance.

 

Having consulted with a number of other providers and commissioners, the more recent rigid implementation of Registering the Right Support which has been reported is rather disconcerting because of the lack of clarity regarding what services might be registered and which might not. During conversations with a number of providers who have recently had registrations rejected, it has highlighted the major concerns for all organisations looking to invest in developing new services for people with learning disabilities and / or autism. The business risks associated with any substantial investments of any type over more recent years have been significant, but the ambiguity that is currently being created by the manner in which Registering the Right Support is being interpreted and implemented is of great concern to all.

 

It takes a significant length of time and capital investment from first conceiving a plan to develop a new service to the point of registration, meaning many businesses have recently had registrations rejected for businesses that were planned ahead of the June 2017 publication. I have felt fortunate that I learned of the ill fate of several proposed developments, literally days ahead of signing off the construction of a brand new 11 bedded service. As a result of the conversations held with providers and commissioners, we have felt it necessary to reduce the business risk of the project by reducing the number of beds within the plans.

 

Whilst not ideal, the decision to do so might have saved the business something in the region of £500K (minus those costs already laid out for planning and design). Others have not been so fortunate!

 

Again, closer regulation of providers for services for people with learning disabilities and / or autism to minimise the risk of harm to individuals is welcomed. However, where the regulator implements a policy that will potentially reduce the number of providers investing in delivering the necessary placements to support people back into community settings from long stay hospitals, this could adversely affect the national Transforming Care policy.

 

There is a contradiction with the approach behind the thinking within Registering the Right Support, which assumes that large services within rural settings are not appropriate for people with learning disabilities and / or autism: there are several ‘Outstanding’ services (as regulated by CQC) for people with very complex needs which are facilitating fantastic outcomes for individuals. How then can CQC deem these services as not being appropriate for people with learning disabilities, when by their own judgement they are rating them as ‘Outstanding’, with very many more being rated as ‘Good’?

 

Further, why is it OK to accept that for ‘older adults’ services, there are economies of scale, which means it is acceptable to have large institutional settings registered by CQC in rural locations for this client group. Surely, the extent of abuse within older adult settings has been documented and reported upon as equally as within younger adult settings, or at least it would be naïve to think that the risks are any less within these settings?

 

Given the apparent discrimination being shown towards ‘Good’ or ‘Outstanding’ providers of residential services to people with learning disabilities and / or autism, surely there is a call for CQC to review their approach to ‘Registering the Right Support’, so that people are in fact able to receive the right support?

edited on Nov 30, 2018 by Adam DHSC

Adam DHSC 2 weeks ago

Moderation status changed: Removed

Not on topic, political and not written from a person

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Adam DHSC 2 weeks ago

Moderation status changed: Clear

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Adam DHSC 2 weeks ago

Thanks for you comments. I wonder if you'd be able to comment on how this has an impact with the workforce?

Adam

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