CQC inspection activity is on the rise

The Care Quality Commission’s (CQC) activity dipped significantly during the Covid-19 pandemic and the introduction of the now-discredited Single Assessment Framework saw inspection activity fall below historic levels.

The CQC has been publicly quiet over the summer while it gets its house in order. and has now launched a new consultation to improve its assessment framework, how it makes judgements and awards ratings.

At HCR Law, we’re seeing a flurry of activity that suggests the CQC is regaining momentum and making inroads into the backlog of assessment activity. CQC noted that it had completed 1,976 assessments between April and July 2025; 443 in April, 452 in May, 540 in June and 541 in July. We’ve seen more inspection reports coming across our desks, which suggests clients are unhappy with their content – whether that’s the facts as set out, any allegations contained within or the resulting judgements being made.

Providers can engage the factual accuracy comment process if they’re not happy with the draft report. They only have 10 working days from the date the report is received to do so. Now that the Provider Portal is being used more widely, providers should be careful not to miss the draft report being uploaded there.

The reports we’ve seen are often vague, repetitive (with the same allegation repeated across different sections of the report, giving the impression of greater concern than usually indicated by the singular fact) and unclear in how scoring has been reached.

Upcoming consultation: scoring and ratings overhaul

The CQC’s consultation proposes changes to the current scoring model, how judgements are made and kept up to date, along with proposals to strengthen the role of professional judgement and simplify the rating process. This sounds like a comprehensive overhaul and we expect the sector will welcome this, given the numerous concerns with the current system. Any changes to the system must be clear, transparent and robust, with providers given the opportunity to challenge any concerns in the report.

While the 10-working-day window for factual accuracy comments has long been in situ, changes introduced with the Single Assessment Framework have made it more difficult for providers to respond to draft reports.

Firstly, factual accuracy comments must now be submitted via the Portal by the provider directly; third parties, such as solicitors, can no longer make submissions on their behalf. This isn’t always helpful, as often there are issues to raise that don’t automatically lend themselves to inclusion on a “table”.

Each section must be responded to separately, which takes time. There’s also a character limit in each section and while it’s possible to upload appendices with representations continued, this is time-consuming and overly complicated – especially given the relatively short timeframe in which a provider has to pass comment.

This process should be made as easy as possible for a provider to provide all the information and documentation it wishes, without being put off from doing so due to the bureaucracy involved.

Sector impact and next steps for providers

HCR Law has recently seen draft reports sent for factual accuracy comments months after the inspection visit. This makes it harder to respond, given the often-vague allegations and passage of time, affecting providers’ ability to recollect or investigate concerns.

As noted, the consultation will examine how judgements are kept up to date – another welcome move by the sector, as judgements have a huge commercial impact on providers. Where we’ve helped clients with older draft reports, the CQC has said it has a statutory duty to publish inspection reports. But this shouldn’t come at the expense of publishing accurate and current information in the public domain.

While the sector awaits further change, it’s important to continue holding the CQC to account by challenging draft reports if they are not reflective of the service. Significant changes to the assessment process aren’t expected until at least 2026.