The 2021 strategy sets out our ambition to assess local systems, and tackle inequalities in health and care, which is supported by our equality objectives.
As part of our new single assessment framework, we are developing an assessment and monitoring framework specific to local authorities (LA) and integrated care systems (ICS) (in line with expectations within the Health and Social Care Act). Our new processes will clearly set out what people can expect in terms of our processes and what CQC expects of local authorities and integrated care systems. We hope to commence assessment and monitoring from April 2023.
We will use the quality statements to help us understand and assess systems including for equality, health inequalities and human rights. Although multiple quality statements will capture these areas (we will build in specific evidence requirements to support staff to uncover concerns and report on specific actions a system is taking to improve equity), we will also look specifically at:
- equity in access (ICS)
- equity in experiences and outcomes (ICS / LA)
- workforce equality, diversity and inclusion (ICS).
Our assessment and monitoring will be informed by:
- data and insights
- the voices of people and communities and their representatives experiencing poor equity in access and outcomes, to understand their experiences and to amplify their voices
- the voices of staff employed by or working within a system (through sharing their experience and system-wide surveys).
This equality impact assessment (EIA) was prepared by our:
- Strategy Manager
- Strategy Officer
- Regulatory Policy Officer.
Equality and human rights risks, opportunities and actions identified
1) Reducing inequalities
Reducing inequalities is a critical cross cutting theme in CQC strategy which must be realised through the assurance frameworks that are developed.
Risk or opportunity
Both.
Action
Ensure that it is explicitly covered within our methodology including the assessment framework, testing, and reporting. (Equity Quality Statement not included in draft for Local Authority Assessment (LAA) Test and Learn, but subsequently inserted within the quality statements in October 2023 following communication with Equality, Health Inequalities and Human Rights (EHIHR) team to ensure a specific and standalone focus on equity)
Action owner
Policy & Strategy LAA/ICS systems teams with sign-off by Heads of teams.
2) Whole system population planning
Whole system population planning needs to consider inequalities in access and outcomes that fall outside protected characteristics. Could include socioeconomic and environment factors.
Risk or opportunity
Both.
Action
Developed in "New risks and opportunities identified" section.
Action owner
Policy & Strategy LAA/ICS systems teams with sign-off by Heads of teams.
3a) Making information available
Need to improve how we make information available to people. This includes easy read, short report format.
Risk or opportunity
Both.
Action
Developed in "New risks and opportunities identified" section.
Action owner
Policy & Strategy LAA/ICS systems teams with sign-off from Heads of teams; Public Engagement team and LAA/ICS Engagement lead; Data & Insight Principle Analysts for Data Insight and Strategic Insight.
3b) Improving how people share their experiences
Need to improve how people can share their experiences of systems and care with us. This includes accessible digital communication, reducing digital exclusion and how we feed back to people who are more likely to receive poor access, experience, or outcomes.
Risk or opportunity
Both.
Action
Developed in "New risks and opportunities identified" section.
Action owner
Policy & Strategy LAA/ICS systems teams with sign-off from Heads of teams; Public Engagement team and LAA/ICS Engagement lead; Data & Insight Principle Analysts for Data Insight and Strategic Insight.
4) Ensuring a good understanding of a system
In any dependencies with digital programmes it is particularly critical to identify equality, health inequality and human rights requirements early to prevent later reiterations and amendments and to ensure we have a good understanding of a system.
Risk or opportunity
Risk.
Action
Developed in "New risks and opportunities identified" section.
Action owner
Regulatory Platform team.
5) Consistent approach to equality, health inequalities and human rights
Need to ensure and embed a consistent approach to equality, health inequalities and human rights across our assessment activity, supported by appropriate training for staff.
Risk or opportunity
Both
Action
Developed in "New risks and opportunities identified" section.
Action owner
Policy & Strategy LAA/ICS systems teams with sign-off from Heads of teams; Organisational Design team, and Academy.
6) Impact of organisation restructure on staff
Need to consider the impact of our organisational restructure on our staff. This includes the design and delivery of our new duties/roles.
Risk or opportunity
Risk.
Action
N/A.
Action owner
Organisational Design team.
7) Operational restructuring
Operational restructuring has created opportunities with new internal teams (Integrated Area Inspection Teams). Their regular engagement with stakeholders will be key sources of evidence for LA and ICS assessment.
Risk or opportunity
Opportunity.
Action
N/A.
Action owner
Organisational Design team.
8) Engaging stakeholders in different quality groups, human rights groups and seldom heard groups
We need to ensure that we proactively engage stakeholders in different equality groups, human rights groups and seldom heard groups as part of the co-production process.
Risk or opportunity
Both.
Action
Developed in "New risks and opportunities identified" section.
Action owner
LAA / ICS Engagement lead and Head of Public Engagement team.
9) Insight from people more likely to experience inequitable outcomes
Evidence requirements include insight from people that are more likely to experience inequitable outcomes with certain evidence requirements noting specific people/communities.
Risk or opportunity
Both.
Action
Ensure that our design methodology uses best practice to inform evidence categories (including people more likely to have inequitable outcomes).
Working with Research Development and Evaluation Committee (RDEC) to ensure current and future research projects inform our approach and methodology. For example, the best practice in tackling inequalities in local areas work.
Action owner
LAA / ICS Policy teams, including Heads of teams; Head of EHIHR team.
10) Improving understanding and analysis of equality and human rights data
We are working to improve our understanding, and analysis of equality and human rights data. This is aligned with national programmes, such as Core 20+5 national priorities for tackling healthcare inequalities.
Risk or opportunity
Both.
Action
Clear data sources are identified/developed by D&I, linked to evidence requirements in our assessment frameworks and are clear when there is possible risk.
Action owner
Data & Insight team: Principle Analyst – Data Insight and Principle Analyst – Strategic Insight; EHIHR Senior Officer; Director and Interim Director of Regulatory Leadership team.
11) Methodology development
Methodology development considers the recommendations and learning from key CQC reports, projects, and internal research and development especially where inequalities have been highlighted including the use of inequality tools.
Risk or opportunity
Both.
Action
Build on previous recommendations and see if relevant at the systems level.
Utilise experience and CQC staff feedback from testing and pilots to inform methodology going forward.
Review our findings in relation to the RDEC best practice in tackling inequalities in local areas work.
Action owner
LA/ICS Policy team (Policy Officers); Head of EHIHR.
12) Public sector equality duties
We need to ensure our 2 system frameworks address/reflect the relevant public sector equality duties.
Risk or opportunity
Both
Action
Look at in the pilots/testing and the draft assessment framework, if possible, revisit ahead roll out. Evaluation of the test and learn – what gaps were identified.
Action owner
LA/ICS Policy team with sign-off from Head of team; EHIHR Manager.
13) Use of terminology/language
Use of terminology /language used should be within our common approach and relevant to terminology used within systems. (For example, deprivation and old definitions). Need for clarity around use of ‘inequality’.
Risk or opportunity
Both.
Action
Review methodology across both frameworks so they are in line with CQC editorial and style guidance.
Ensure the EHIHR team are satisfied with our use of terminology across the evidence requirements.
Action owner
LA/ICS Policy team with sign-off from Head of team; EHIHR Manager.
New risks and opportunities identified
14) Potential impact of proposal: Themes at systems level
Identifying within our frameworks equality, health inequality, human rights issues, concerns and best practice at system level will support local hubs to identify themes at a systems/area level and ensure consistency of approach across CQC. This should be supported through the training programme.
Risk, opportunity or both
Both
Who is affected?
- Public
- Providers
- CQC staff
- Others.
Equality characteristics or human rights
All.
Supporting evidence
Related to Action 2.
15) Potential impact of proposal: Accessible ways to communicate
Through our public engagement team, develop accessible ways for people to communicate with us through the experience framework and tools to ensure that we effectively capture and reflect their experience and identify human rights/equality and health inequality concerns. Including the way that we publicly report and share findings and prevention of digital exclusion.
Risk, opportunity or both
Both.
Who is affected?
- Public
- CQC staff.
Equality characteristics or human rights
People with information and communication needs related to a disability or sensory impairment, who speak another language or have English as a second language, and those experiencing digital exclusion through poverty.
Supporting evidence
Related to Action 3.
16) Potential impact of proposal: Including people impacted
Engagement plan for the new assessment frameworks to ensure consideration of equality and human rights by including people indirectly impacted by change as well as those directly impacted (for example, people who use services indirectly impacted by changes to our expectations of providers), and proactively engage stakeholders in different equality groups and representing those who experience health inequalities (co-production).
Risk, opportunity or both
Both.
Who is affected?
- Public
- Other (stakeholders in different equality groups).
Equality characteristics or human rights
All –work with Public Engagement Lead to include People’s Experience workstreams, and confirm with engagement colleagues that these stakeholders included within co-production engagement.
Supporting evidence
Related to Action 6.
17) Potential impact of proposal: Innovation and good practice
Identify and support innovation and good practice focused on reducing health and care inequalities at system level.
Our evidence requirements will reflect national best practice and we will communicate through our processes when we see good practice. How will we ensure that our work highlights good practice and that it is embedded as an ongoing improvement process?
Risk, opportunity or both
Both.
Who is affected?
- Public
- Providers
- Systems (ICS/LA).
Equality characteristics or human rights
All.
Supporting evidence
N/A.
18) Potential impact of proposal: Development of assessment frameworks
Ensure that the development of the assessment frameworks identify, assess and address equality, health inequality and human rights issues effectively and robustly.
Risk, opportunity or both
Both.
Who is affected?
- Public
- Providers.
Equality characteristics or human rights
All.
Supporting evidence
N/A.
19) Potential impact of proposal: Alignment with single assessment
Alignment with CQC single assessment framework, ensuring that they reflect outcomes needed for all equality groups and people who are more likely to experience inequality.
Risk, opportunity or both
Both.
Who is affected?
- Public.
Equality characteristics or human rights
All.
Supporting evidence
N/A.
20) Potential impact of proposal: Need for in-depth insight
Assessment teams want more in-depth insights and equalities information beforehand to enable better assessments.
Risk, opportunity or both?
Both.
Who is affected?
- CQC staff.
Equality characteristics or human rights
All
Supporting evidence
N/A.
21) Potential impact of proposal: Secretary of State objectives and priorities
Secretary of State will have the power to set objectives and priorities for this work, which could impact upon key themes.
Risk, opportunity or both
Both.
Who is affected?
- All.
Equality characteristics or human rights
All
Supporting evidence
Groups likely impacted
CQC staff
Likely impacted by sections: 1, 2, 4, 5, 6, 7, 8, 9, 10, 12, 14, 15, 16, 20 and 21.
Public/people who use services
Likely impacted by sections: 3a, 3b, 4, 8, 9, 14, 15, 18, 19, 20 and 21.
Providers
Likely impacted by sections: 1, 13, 14, 17, 18 and 21.
Others
Likely impacted by sections: 1, 2, 8, 9, 10, 13, 14, 17, 18, 19 and 21.
Action plan
Overall Regulatory Framework and Model
Action 1
This affects items: 1, 2, 5, 10, 11, 14 and 21.
Action required
In the design of our new approach, we consider equality, diversity and human rights issues and the impact of systems on people who are more likely to experience poor health and wellbeing outcomes. We will review learning and recommendations from previous CQC work (themed reviews and reports), will help to inform our assessment framework and to protect the human rights of people and prevent discrimination through embedding those learning outcomes within our new assessment methodology.
Action owner
Policy & Strategy Head of Systems.
This relates to an Equality Objective: 1, 2 and 3.
Target start date: N/A.
Target/actual completion date: End of 2022.
Action 2
This affects items: 3a, 3b, 5, 7, 8, 9, 10 and 16.
Action required
In developing, reviewing, and re-designing our new approach, we are valuing and embracing feedback from people who use services including people whose voices are seldom heard; voices from different stakeholders including providers, Experts by Experience, VCSE organisations, and organisations representing people (such as Healthwatch). This includes Citizen lab surveys and co-production engagement events.
Action owner
Policy & Strategy Head of Systems and Engagement System lead.
This relates to an Equality Objective: 1 and 3.
Target start date: N/A.
Target/actual completion date: April 2023.
Action 3
This affects items: 2, 5, 10, 14 and 20.
Action required
As we develop our approach we are building our understanding of how to assess how the systems know the needs and preferences of local populations, particularly people who are more likely to have poor access, experience or outcomes in health and care. This will help us assess and hold systems to account effectively and ensure services improve for all. This is part of our wider equalities objectives which includes using data to understand and respond to equality risks.
Action owner
Head of Analytic Content team; Responsible owner, RDEC research project; Public Engagement team lead.
This relates to an Equality Objective: 1, 2, 3 and 4.
Target start date: June 2022.
Target/actual completion date: Ongoing during development and make-normal stage.
Action 4
This affects items: 1, 2, 3a, 5, 14, 18 and 19.
Action required
Our up-to-date view of quality will start from April 2023 as we build a picture of how systems use an integrated, evidence-based, population-wide approach to address and reduce health inequalities and the wider determinants which drive these inequalities. This will help us strengthen our equality decision-making and enable us to be proactive and reactive in terms of risks to people and communities. (The National Quality Board updated shared commitment to quality will be used as a benchmark). This will provide a basis for our wider equalities research looking at ‘what works in tackling inequalities’.
Action owner
Policy & Strategy Head of Systems; Head of EHIHR team.
This relates to an Equality Objective: 1, 2, 4 and 5.
Target start date: April 2023.
Target/actual completion date: Ongoing during development and make-normal stage.
Action 5
This affects items: 10, 11, 12, 14 and 21.
Action required
We are building into our assessment frameworks and methods known equality issues and best practice around access to and outcomes from care, such as issues for people from ethnic minority groups, older people and disabled people including right to life issues, seldom heard communities, underserved populations, people more likely to experience health inequality and inclusion health groups.
Action owner
Policy & Strategy Head of Systems; Head of EHIHR team.
This relates to an Equality Objective: 1 and 2.
Target start date: N/A.
Target/actual completion date: April 2023.
We assess the performance of LAs and ICSs and may rate them
Action 6
This affects items: 1, 2, 5 and 18.
Action required
In our new assessment framework we will make clear what we expect of systems and services to meaningfully involve people in decisions about their care, so they receive high quality care and live their lives as they want –particularly people and communities who are more likely to experience discrimination and exclusion.
Action owner
Head Of Public Engagement; Head of Analytic content.
This relates to an Equality Objective: 1.
Target start date: N/A.
Target/actual completion date: April 2023.
Action 7
This affects items: 5, 8, 10 and 18.
Action required
Within the new assessment framework, people's experiences of care will be captured and used to inform our system assessments and where appropriate how we assess and rate services (using the People’s Experience Framework). This will include variation in people’s experiences, for example where some groups of people receive good care when others do not. We are specifically undertaking Local inequalities outreach project, as a new way of capturing information.
Action owner
Policy & Strategy Head of Systems.
This relates to an Equality Objective: 1.
Target start date: April 2023.
Target/actual completion date: Ongoing during development and make normal stage.
Action 8
This affects items: 3a, 3b, 5, 8, 10, 13, 14, 15, 17 and 19.
Action required
Ensure that within the new assessment framework, we will be linking the wide range of information that we gather with feedback people give us and reporting this in a transparent and accessible way.
Action owner
Policy & Strategy systems – Regulatory Policy Manager; Regulatory Leadership - Director of Adult Social Care and Interim Director of Integration, inequalities and improvement.
This relates to an Equality Objective: 2, 3, 4 and 5.
Target start date: April 2023.
Target/actual completion date: Ongoing during development and make normal stage.
Action 9
This affects items: 5, 11, 3a, 3b, 4, 16 and 18.
Action required
We are aligning our engagement and assessment approaches with national expectations around equality, health inequalities and human rights such as those in the NHSEI Health Inequalities Priorities.
Action owner
Head of EHIHR team, Head of Public engagement, Head of Operational insight.
This relates to an Equality Objective: 1 and 2.
Target start date: April 2023.
Target/actual completion date: Ongoing during development and make normal stage.
Action 10
This affects items: 5, 11, 3a, 3b, 4, 16 and 18.
Action required
We are aligning our engagement and assessment approaches with national expectations around equality, health inequalities and human rights such as those in the NHSEI Health Inequalities Priorities.
Action owner
Head of EHIHR team, Head of Public engagement, Head of Operational insight.
This relates to an Equality Objective: 1 and 2.
Target start date: April 2023.
Target/actual completion date: Ongoing during development and make normal stage.
Action 11
This affects items: 1, 5, 10, 12, 17 and 21.
Action required
Need to strengthen leadership section to include inequality assessment and understanding, what priorities, what is measured and tracked and how? How do LAs and ICS decide to embed which national priorities as local?
Action owner
Policy & Strategy – Regulatory policy manager; EHIHR Senior officer / manager.
This relates to an Equality Objective: N/A.
Target start date: Oct 2022.
Target/actual completion date: Feb 2023.
We take action to escalate concerns or risks
Action 12
This affects item: 18.
Action required
We are considering learning from escalation processes, and working with DHSC on how to escalate emerging concerns including equality and human rights issues.
Action owner
Policy &Strategy - Head of systems.
This relates to an Equality Objective: 3.
Target start date: April 2023.
Target/actual completion date: Ongoing during development and make normal stage.
We share and publish our findings to inform and influence improvement
Action 13
This affects items: 3a, 5, 13, 15, 17 and 21.
Action required
We will share what we find with systems to enable them to drive improvement in equal access, experiences and outcomes, and independent voice.
This links to our equality objective ‘working with others to improve equality of access, experience and outcomes’.
Action owner
Policy & Strategy - Head of Systems; Head of Editorial.
This relates to an Equality Objective: 4 and 5.
Target start date: April 2023.
Target/actual completion date: Ongoing during development and make normal stage.
We provide assurance in a local area (LA and System)
Action 14
This affects items: 2, 5, 7, 8, 9, 15, 16, 18 and 21.
Action required
We are ensuring that our new regulatory model and assessment framework will support developing our understanding of where there are gaps in oversight, to ensure that people’s equality and human rights are maintained, health inequalities are reduced and good care is provided for all.
Action owner
Policy & Strategy - Head of Systems.
This relates to an Equality Objective: 1, 2 and 3.
Target start date: April 2022.
Target/actual completion date: Ongoing during development and make normal stage.
Action 15
This affects items: 3a, 5, 13, 15, 17 and 21.
Action required
We will be ensuring that our findings include how systems identify and act on inequalities.
Action owner
Policy & Strategy - Head of Systems.
This relates to an Equality Objective: 4.
Target start date: April 2023.
Target/actual completion date: Ongoing.
Action 16
This affects items: 2, 5, 10 and 14.
Action required
We will work towards ensuring that our assessment framework will supports us to consider how new improvement coalitions embed reducing inequalities into improvement support.
Action owner
Policy & Strategy - Head of Systems.
This relates to an Equality Objective: 3 and 4.
Target start date: April 2023.
Target/actual completion date: Ongoing.
Action 17
This affects items: 8, 11, 13, 15 and 16.
Action required
We will continue to evolve and develop tools to assess how local systems seek out, listen, and respond to people who are more likely to experience poor health and wellbeing outcomes.
Literature reviews and research commissioned by the research and development team to explore characteristics of effective systems and best practice in tackling inequalities in local areas will help inform this area. We will evolve and develop tools informed by this.
Action owner
Policy & Strategy - Head of Systems, Head of Public engagement.
This relates to an Equality Objective: 1, 2 and 3.
Target start date: April 2023.
Target/actual completion date: Ongoing.
Action 18
This affects items: 5, 6, 7, 10 and 20 .
Action required
CQC staff will be appropriately trained and supported to consider equality, diversity, and human rights implications in their assessment of systems.
Action owner
Academy learning & development advisors.
This relates to an Equality Objective: 1, 2 and 3.
Target start date: April 2023.
Target/actual completion date: Ongoing.
Action 19
This affects items: 5,10,12 and 14.
Action required We will make better use of information on inequalities gathered by local Healthwatch and other local partners to drive improvement.
Action owner
Head of Public engagement.
This relates to an Equality Objective: 1, 2 and 3.
Target start date: January 2023 onwards.
Target/actual completion date: Ongoing during development and make normal stage.
Action 20
This affects items: 1, 5 and 21.
Action required
Embed our core strategic commitment to protecting human rights through our approach to assessing systems (LAA/ICS), from design to roll out.
Action owner
Policy & Strategy – Head of Systems, Head of EHIHR team.
This relates to an Equality Objective: N/A.
Target start date: Oct 2022.
Target/actual completion date: Ongoing during development and make normal stage.
Action 21
This affects item: 14
Action required
Ensure our staff have access to up to date, key best practice guidance for each quality statement.
(Alongside specific training, each evidence requirement section will include best practice guidance.)
Action owner
P&S systems development team.
This relates to an Equality Objective: N/A.
Target start date: November 2023.
Target/actual completion date: Ongoing.
Action 22
This affects item: 17.
Action required
Strengthen the best practice section of the assessment framework to support operational staffs knowledge and skills when undertaking an assessment or when making a judgement about a system.
Action owner
P&S systems development team.
This relates to an Equality Objective: N/A.
Target start date: November 2023.
Target/actual completion date: Ongoing.
Action 23
This affects item: 20.
Action required
D&I work with key stakeholders, including DHSC, NHSE to shape and improve available data.
Action owner
Principal Analysts, Data Insight and Strategic Insight.
This relates to an Equality Objective: 1 and 2.
Target start date: April 2022
Target/actual completion date: Ongoing during development and make normal stage.
Action 24
This affects items: N/A.
Action required
Workforce equality, diversity and inclusion – ICS quality statement links to the work programme on workforce, to improve our systems data (both quantitative and qualitative).
Action owner
ICS lead, P&S Head of systems, EHIHR Senior officer.
This relates to equality objective: N/A.
Target start date: Ongoing.
Target/actual completion date: Various end dates for different elements.
Action 25
This affects item: 13.
Action required
Link to the ongoing joint work with ALBs on tackling health inequalities – including development of a joint position statement.
Action owner
ICS lead, Head of EHIHR team.
This relates to an Equality Objective: N/A.
Target start date: October 2022 onwards.
Target/actual completion date: End date not yet confirmed.
Sign off
This equality impact assessment was signed off by:
- Dave James and Matthew Tait (Head of LAA/ICS development): 21 November 2022.
- Lucy Wilkinson, Head of Equality, Health Inequalities and Human Rights for final sign off: 10 August 2023.
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