For digital providers, the consultation on the CQC’s new strategy is an opportunity to highlight how the regulatory process could, and should, be making better use of what digital services can offer. As a collective voice of 17 digital health providers, we responded with our thoughts on how the new strategy could help meet the needs of the evolving healthcare system. We’re continuing our engagement with the CQC over the coming months and look forward to supporting them in addressing some of the more operational challenges.

Focusing on four key themes; people and communities; smarter regulation; safety through learning; and accelerating improvement; the CQC’s new strategy outlines the changes the regulators intend to make over the next five-years. It is aimed at improving care by looking at how well health and care is currently working and how it’s reducing inequalities. Broadly speaking as the DHC we welcome the proposals set out in the strategy but, see opportunities to improve the way care is regulated by considering what else digital providers have to offer.   

We’ve considered each of the four themes in turn, looking at how digital services can help to improve regulation and ultimately improve care for patients.

People and communities

“We want our regulation to be driven by people’s experiences and what they expect and need from health and care services. We’ll focus on what matters to the public, and to local communities, when they access, use, and move between services.”

We strongly agree with the CQC’s commitment to a regulatory approach that focuses on listening and responding to end-users. As healthcare providers, patients should be at the centre of everything we do and therefore they should have a say in directing how care is delivered. Digital providers are extremely well placed to collect and act on patient data about their experiences and preferences. There is a real opportunity for the CQC to put this to better use. We’re keen to ensure that the CQC makes the best use of the measures around patient engagement and feedback, both in the digital space and also considering how to address the gaps in more traditional face-to-face provision.

What’s more, the addition of digital provision to the healthcare ecosystem means that patients now have many more options about how they can access their care, and this could play an important part in helping to address the growing concerns around health inequalities. In fact, many of our members are seeking to address the inequalities that have been made increasingly apparent by the pandemic – CheckUp Health provides a great example.

As patients’ expectations of care continue to change, it’s increasingly important that patients have access to the right care in the right format for them.   

Smarter regulation

“We want our assessments to be more flexible and dynamic. We’ll update ratings more often, so everybody has an up-to-date view of quality. Being smarter with data means our visits will be more targeted, with a sharper focus on what we need to look at.”

To echo above, digital providers naturally create and rely on rich datasets that vary quite significantly from those collected by traditional providers either in scale, granularity or coverage. This poses profound questions about how to:

• Compare information collected by digital providers with that collected by more traditional services;
• develop data collections by traditional face-to-face services to meet the scale of information that can be collected by digital providers;
• allow flexibility for providers to collect information that makes sense for their own specialism of service while also collecting information that fulfils the regulatory requirements.

The practical reality of how these questions can be addressed remains uncertain. But, we believe a good starting point is considering how data held by digital providers could be used to improve our understanding of patient access to care.

Safety through learning

“We want all services to have stronger safety cultures. We’ll expect learning and improvement to be the primary response to all safety concerns in all types of service. When safety doesn’t improve, and services don’t learn lessons, we’ll take action to protect people.”

Safety underpins everything healthcare providers do. In line with that, we support the steps that the CQC intends to make to improve safety and to foster a learning environment. We recognise that the remote delivery of services can pose new questions about how to ensure safe care. But, we also know that digital provision offers significant opportunities to improve safety through increasing access and through more profound changes in how we monitor patients.

Accelerating improvement

“We want to do more to make improvement happen. We’ll target the priority areas that need support the most. We want to see improvement within individual services, and in the way they work together as a system to make sure people get the care they need.”

Continuous iteration and improvement are fundamental to modern digital development and service delivery. We innovate, implement, collect data, measure effectiveness, and begin the cycle all over again. We believe that there is always scope for improvement and it’s crucial that regulatory approaches keep pace with and encourage such innovation.

It’s clear this is the only the beginning of the CQC’s journey towards and we’ll look forward to working with the CQC over the coming weeks, months and years as they work to implement the strategy.

If you’d like to see our full response to the consultation or to hear how we’re engaging with the CQC to inform the implementation of the strategy, please get in touch.