VODG consultation response
Care Quality Commission consultation on Regulatory fees – have your say: proposals for fees from April 2016 for all providers that are registered under the Health and Social Care Act 2008
About us
Voluntary Organisations Disability Group (VODG) is the national body that represents over 80 leading voluntary and charity social care disability care providers. Members work with around a million disabled people throughout the UK, employ more than 85,000 staff and have a combined annual turnover in excess of £2.6 billion. Most of the services delivered by VODG member organisations are registered with the Care Quality Commission (CQC). We are therefore very well placed to comment on the proposal document and act as an authoritative point of contact with the CQC.
Though diverse in terms of their size, history and individual strategies, VODG member organisations share common values. These are clearly discernible through work that promotes the rights of disabled people, approaches to citizenship, user choice and control and in successfully delivering person-centred services. We are members of Think Local, Act Personal and fully uphold principles for full choice and control for everyone with a disability. In addition, VODG members lead the sector in terms of its investment in the social care workforce and the development of new and innovative service models.
We are happy to work in a collaborative and cooperative way with CQC and are actively engaged in CQC’s adult social care co-production events, the trade associations meeting, the housing with care expert reference group and the fees advisory panel. However, we will only continue to do this when we can add value through our views being heard and acted upon.
Why VODG disagrees with CQC’s proposal to increase annual fees
We disagree with the premise that fees should be based on full cost recovery. The regulation and inspection of services is an activity which is primarily driven by public interest. Providers have a part to play in meeting these costs, but not exclusively. This basic premise has been overlooked by both the Treasury and CQC.
Fees should be based on a clear, costed strategic plan. Therefore we believe that the conversation about fees should take place alongside and be allied with a consultation on costed proposals for the CQC strategy 2016-21. It makes no sense to consult on fees now, when there is no information publicly available about the costs of delivering CQC’s new 5-year strategy.
The proposed fee increases are clearly entirely out of step with the financial pressures which are currently impacting on social care providers. During last year’s fee consultation, VODG provided a thorough response which articulated the collective view of our member organisations and detailed the arguments why CQC should not increase fees. These include:
- As the regulator with responsibility for market oversight, CQC must understand that the sector is close to collapse and not add any additional financial burden to services.
- Arguments based on full cost recovery are out of step with the sector; commissioners are basing fee levels on affordability.
- CQC has expanded while the rest of the sector has been delivering efficiencies.
- We see wasteful practices by CQC, such as paying exorbitant hotel costs.[1]
- CQC has not demonstrated that it represents good value for money. Our members continue to express concerns about delays in the registration process, long waits for the publication of inspection reports, poor advice and compromised inspection processes (such as a service being inspected by a former employee).
Last year we were not listened to when the fee increase was consulted on and then introduced. This year we are particularly concerned about the proposed fees increases facing community services. We anticipate that, if this goes ahead, it will provoke a tactical response from providers whereby they seek to register more services under one location in order to reduce costs. This will further encumber an already underperforming registration function.
What does VODG propose?
Over the last few years, providers have made huge efficiencies while CQC turnover has increased by £44.4M since 2013/14. Therefore, we are suggesting that, like provider organisations, CQC assesses what it would take for it to operate within its means. We believe that this would be a more appropriate response than passing on to providers the costs of CQC expansion, and would demonstrate a real understanding of the dynamics operating within the health and social care market.
To this end we suggest that CQC models 25% and 40% savings on all chargeable activity; this would reflect a Treasury requirement for CQC to model savings on activity which is funded through grant-in-aid.
We propose that CQC delivers substantial efficiencies and thereby reduces the costs of chargeable activities with a consequent reduction in pressure on fees.
Feedback from our members strongly indicates that it is completely untenable for CQC to reach full cost recovery in two years without a significant detrimental effect on the social care market. Therefore we do not support the two-year option.
We suggest that the four-year option, if coupled with substantial savings by CQC, gives the best possibility of a fair fee structure.
Finally we specifically request that CQC is explicit about costs of proposals being considered within its strategic review and about how these costs will be met.
We look forward to receiving CQC’s response to these points, and understanding how CQC has listened to and acted on our feedback, and that of other providers.