I’m feeling very measured this week.
I spent two days learning about the NHS regulatory regimes with Monitor – the sector regulator for health services in England, described as ‘making the health sector work better for patients’ and the Care Quality Commission, the independent health and adult social care regulator, described as ‘to make sure health and social care services provide people with safe, effective, compassionate, high-quality care’.
Next week, the Derbyshire Healthcare NHS Foundation Trust Board will be considering our plans for the upcoming CQC inspection. On Thursday and Friday last week, the school where I am a governor (Lady Manners at Bakewell) had its OFSTED examination – Ofsted inspect and regulate services that care for children and young people, and services providing education and skills for learners of all ages.
Managers, head teachers and non-executives like me, variously fear, respect, value and trust/ distrust regulators. In every case, people running organisations take these inspections seriously, at least they should. The inspection regimes, whatever you make of them, are a way of the public gaining assurance that the public money these organisations spend is well-spent.
Leading the Peak District National Park meant that I went through two inspections, our ‘National Park Authority Performance Assessments’. I took part in inspections of other parks too and also helped out and commented on the inspections that many of the local authorities went through.
There are some common themes and I’ve picked out 5 here from my experience.
Get an accurate picture
It’s a difficult balance for regulators and those preparing to be assessed to do the job of understanding an organisation’s performnce proportionately. If, as the NHS Foundation Trust I sit on, over 3000 people look after 90 000 service-users in over 100 locations, getting an accurate picture on an inspection can be difficult.
If a secondary school has in excess of 60 classes being taught at any one time, the inspectors can only get a snapshot on their two day visit. Good organisations plan their inspections, work with the regulators in a methodical way and help them get as accurate a picture as they can.
Preparation and data are key
In large and complex organisations, performance data – exam results, patient waiting times and costs per unit of activity - are vital. Good, well-presented and accurate material is vital to help the regulators know what’s happening in a school or hospital.
Good regulators also keep a close eye on all of the data and take a ‘risk-based’ approach to the matters they inspect. For OFSTED inspections, the school performance data is a very important part of the assessment.
Expertise amongst the regulators
A consultant emergency consultant will have a good idea of a well-run emergency department. An experienced psychiatric nurse will have a good idea of a well-run secure unit and an experienced senior teacher will be well-placed to judge great lessons and a school culture.
I think assessment teams need generalists who can ‘ask the penetrating but sometimes simple question’ but so too they need expertise.
I recall digging away for 3 days to understand the conservation work of a national park, sifting reports, talking to staff and stakeholders. I wanted to know how able, ambitious and effective they were and was confident in my final assessment. The local authority accountant on the same team gave the organisation’s corporate systems a good going over, but he would have been lost on what I was examining. The CQC has recently reformed its inspection regime, increasing the expertise of its inspection teams.
It’s all about learning and improvement
An inspection is a fantastic opportunity to learn –whether you are assessing or being assessed. It’s a great chance to reflect too and to use the opportunity of preparation to test out whether things are as effective or well-run as you want them to be.
The data that’s gathered by inspectors, speaking to your staff, service-users, stakeholders and senior teams is vital and can be useful to any manager and leader, however on the ball they are. The documents and evidence you gather in preparation can be valuable resources too.
Follow the rules, but be a little independent
Most inspections follow a defined set of areas of inquiry, often referred to as ‘Key Lines of Inquiry’. These vary from sector to sector and can be subject to the latest political fad or reaction to ‘events’. OFSTED, for example has lots in today about British values and the health regulators are strongly influenced by lessons-learned from the Mid Staffordshire Health Trust experience.
Of course, you’d be mad not to follow the guidance and the KLOEs as you tell the story of your organisation – after all it’s one way of giving the inspectors an accurate picture. But don’t be afraid to show them - on the ground and in some detail - what you are special at, what you are proud of, or where you are working to overcome real challenges and adversity.