Little more than 18 months after the roll-out of the CQC's much-criticised 'Single Assessment Framework' in March 2024, the CQC has now launched a consultation on proposed changes to how it assesses and rates health and social care providers.
Much of what the CQC is proposing will sound familiar as it largely represents a return to the position as it was before the Single Assessment Framework was introduced, including the re-introduction of 'rating characteristics' to assess the quality of health and social care provision instead of the current numerical scoring system.
In this briefing, we look in more detail at these proposed changes.
What are the key changes being proposed?
The CQC's consultation on proposed changes to its assessment approach - 'Better regulation, better care' - was launched on 16 October 2025 and comes in response to heavy criticism of the current 'Single Assessment Framework' (SAF), including in several independent reports.
Importantly, there are no proposals to change the 5 'key questions' (i.e. are services safe, effective, caring, responsive and well-led). The ratings levels (i.e. 'outstanding', 'good', 'requires improvement' and 'inadequate') will also remain as they are. However, the way in which the CQC assesses providers and determines ratings against those key questions would change, in many respects marking a return to how things were done pre-SAF. As the CQC itself says in the consultation foreword: "Some of these proposed changes return us to the best of what we had before".
The headline changes being put forward are as follows:
Farewell 'single' assessment framework
The one-size-fits-all approach of the current SAF does not seem to have worked and the CQC is therefore proposing to introduce sector-specific assessment frameworks, to "more clearly reflect and articulate the context of those health and care sectors". Although the consultation does not detail the sector-specific frameworks the CQC has in mind, the suggestion is that there would be more than just two frameworks as existed pre-SAF (when there was one for health and one for social care).
The plan is to maintain a high degree of consistency across these assessment frameworks, whilst also reflecting differences where needed, which should help the CQC when looking across care pathways. The CQC also proposes to simplify the language used and to remove content that is duplicated across different key questions.
Alongside the frameworks, the CQC intends to publish detailed supporting guidance, setting out the key standards and sources of evidence it will consider for the services in each sector.
The return of 'rating characteristics'
Prior to the introduction of the SAF, the CQC awarded ratings by making a judgement based on 'rating characteristics', which described what its expectations were for each of the 4 possible rating levels, supported by a framework of 'key lines of enquiry' (KLOEs) and 'prompts'. The SAF replaced all that with a numerical scoring system based around a set of 'quality statements', which was intended to bring greater consistency and transparency to ratings decisions. However, the scoring system has proven to be complex and inflexible, with people feeding back that they valued the detail and nuance of the previous rating characteristics.
The CQC is therefore proposing to revert back to the pre-SAF approach of inspection teams considering all the evidence they collect under each key question and making a judgement with reference to rating characteristics which the CQC will develop and publish. To support the rating characteristics, the CQC proposes to develop a framework of 'supporting questions', similar to the previous KLOEs, to replace the current quality statements.
Under these proposals, the existing scoring system would become a thing of the past, marking a return to professional judgement playing more of a role in ratings decisions.
New plans for frequency of assessments
The CQC intends to introduce an updated approach to planning assessments and updating ratings.
Under these proposals, there would be two main types of inspection activity supporting the CQC's ongoing assessments of providers:
- Routine planned inspections - taking place on a 3 to 5 year cycle, depending on the type of service and on changes in quality over time, with the consultation referring to the introduction of a 'frequency schedule' for individual sectors
- Rapid response inspections - where immediate and specific concerns are identified
The consultation says that, when updating ratings, the CQC intends to minimise the mixing of new evidence with evidence gathered in previous inspections, especially where those inspections were carried out several years previously. It also says the CQC will consider evidence for both positive and negative changes in quality when scheduling routine inspection activity, which may provide some reassurance to providers which are improving but may feel stuck with old ratings which do not necessarily reflect their current performance.
Trust-level ratings could make a comeback
When the CQC introduced its current assessment methodology, it changed its approach to rating NHS Trusts and began publishing a single rating for the 'well-led' question, which replaced the previous 'overall' quality rating for NHS Trusts. The CQC also stopped publishing Trust-level ratings for the other key questions. However, the CQC is considering reverting back to the previous position on this too, by re-introducing an overall quality rating for NHS Trusts, alongside a supporting structure of Trust-level ratings for all 5 key questions.
Alongside this, the CQC is seeking views on whether to remove aggregated ratings for individual hospital locations for NHS acute trusts and independent hospitals, because aggregating a large number of service ratings within a hospital location can hide variations in the quality of services.
What next?
The consultation is open to everyone to have their say, including providers, partner organisations, people who use services, and members of the public, with the consultation remaining open until 5pm on 11 December 2025. The CQC website includes details of how to respond.
The CQC will then consider the feedback and publish a response explaining how this has helped shape its decisions.
What we do not yet know, however, is how long it may take for the proposed changes to be implemented, particularly in light of the news on 23 October 2025 that Sir Julian Hartley has resigned his role as Chief Executive of CQC. There is no timeline included in the consultation, but there will be a lot of preparation work to be done - e.g. the consultation says the CQC intends to publish draft sector-specific frameworks on its website as part of co-production of their content. All this will take time. Until then, CQC assessments will continue to be carried out using the existing SAF model.
