This equality impact assessment relates to changes that we are making to our framework and approach to assessing local authorities following the initial period of baseline assessment activity.
It aims to identify and assess the impact and any risks from our decisions on specific groups of people. It also aims to improve how we identify any good or outstanding practice within a local authority, that results in more equitable access, experience or outcomes for groups of people.
The framework and approach for assessing local authorities have been informed by what we have learned from our baseline assessment activity and engagement with a wide range of stakeholders.1
Our model for assessing local authorities introduces a more flexible approach with a greater focus on listening to people’s voices, including unpaid carers, to drive improvement. It focuses on their experiences of care and support, as well as their outcomes. We define people’s experiences, including those of unpaid carers, as “a person’s needs, expectations, lived experience and satisfaction with their care, support and treatment, including equity of experience, access to and transfers between services”.
The key changes in the assessment framework and approach for local authorities include:
- Introduction of regular assurance meetings with each local authority to develop our understanding of local risks and opportunities to inform decisions about formal assessment activity.
- Introduction of rating characteristics to suggest what care and support, and governance and leadership might look like for each quality statement across each judgement level in the assessment framework. These characteristics emphasise our expectations around equality across all quality statements.
- Improved emphasis on unpaid carers within the assessment framework through strengthened wording to the quality statements, operational guidance and rating characteristics. The quality statement focusing on equity of experience and outcomes remains in the framework, alongside the golden thread across all quality statements.
- Widening the type of assessment activity to include comprehensive and focused, along with Independent Voice activity. Focused assessments will support us to explore particular aspects of care delivery and provide greater depth on key priority areas.
- Increased use of the professional judgement of assessment teams, supported by a range of tools to ensure consistent and fair judgements, to give more prominence to the voice of people, including unpaid carers.
Evidence and engagement log
We carried out internal and external engagement to inform the key changes to our assessment approach for local authorities. We engaged with government and strategic partners, local authority stakeholders, providers, representatives from Voluntary, Community and Social Enterprise (VCSE) organisations and Experts by Experience, including unpaid carers. The VCSE organisations represented carers, older people, people with a range of disabilities, and people with mental health needs.
In preparing this Equality Impact Assessment, we have drawn on the key messages from this engagement and relevant learning from our baseline assessments to date. We have also reviewed the equality impact assessment for our previous approach.
Purpose of engagement activity
Engagement activity was designed to be small scale and targeted. We held online workshops, focus groups, and gathered feedback on rating characteristics on our online participation platform.
We asked specific questions about how we can improve the focus on people and carers in our assessments and if the existing quality statements capture priorities for people. We also asked how our assessment reports can better reflect the focus on people and unpaid carers.
Feedback from our engagement informed our approach. For example, we heard from our engagement with VCSEs and Experts by Experience that unpaid carers’ experiences could be strengthened in our assessments. Our updated approach to assessing local authorities now gives more emphasis and prominence to issues relating to unpaid carers in our assessment activity, judgements and reporting.
Key insights from engagement included:
- Support for CQC placing more emphasis on the experiences of people including unpaid carers in assessments: VCSE organisations and Experts by Experience felt that the experiences and outcomes of people, including unpaid carers, should be given more emphasis in the assessment framework. There was also support for carers experiences and quotes to be more visible in the assessment reports.
- More accessible assessment reports: VCSE organisations and Experts by Experience said they would like to see more accessible assessment reports, with clearer language and more prominence given to unpaid carers in the reports. For example, avoiding grouping them together by using the term ‘people who use services.’ There was also support for easy read versions of assessment reports.
- Need to improve how we reach and involve carers in the assessment process: Experts by Experience felt we could improve how carers are contacted to come forward during an assessment to share their experiences, so their voices are heard.
Impact on protected groups
We look at the potential risks, opportunities and impact for people with protected equality characteristics in the following areas, and people in other specific circumstances:
Age
(People of different ages, children).
Potential impact/s to consider:
- People who come into contact with local authority adult social care services, including unpaid carers, and children and young people such as young carers, or young people preparing to transition to adult social care services, who have additional vulnerabilities or needs.
- Any equity issues for people of different ages who work in social care services, which might have an impact on the quality of care.
Disability
(Disabled people, including people with mental health needs).
Potential impact/s to consider:
- People who come into contact with local authority adult social care services, who have additional needs because of disability, who have a right to reasonable adjustments or who may face discrimination.
- Any equity issues for disabled people who work in health and social care services, which might have an impact on the quality of care.
Gender reassignment
(Trans people and non-binary people).
Potential impact/s to consider:
- People who come into contact with local authority adult social care services, who have additional needs because of gender reassignment or gender identity, or who may face discrimination.
- Any equity issues for trans or non-binary people who work in social care services, which might have an impact on the quality of care.
- Although our assessments refer to the Equality Act 2010, CQC does not set national policy on issues such as single-sex care provision, and we are not the primary regulator of the Equality Act 2010.
Following the Supreme Court ruling on the definition of sex under the Equality Act, we will review any implications for our assessment approach, taking account of national policy decisions and EHRC guidance as it emerges. Our regulatory stance remains that everyone must be treated with dignity and respect, free from harassment and discrimination.
Marriage and civil partnership
(A person has the protected characteristic of marriage and civil partnership if they are married or are a civil partner).
Potential impact/s to consider:
- This characteristic must be considered in relation to eliminating unlawful discrimination in employment, for example in Equality Impact Assessments relating to impacts on our workforce. We do not expect it to be relevant to this external facing, non-employment related work.
Pregnancy and maternity
Potential impact/s to consider:
- People who come into contact with local authority adult social care services, who have additional needs because of pregnancy or maternity.
- Any equity issues for pregnant women or women with maternity protection who work in adult social care services, which might have an impact on the quality of care.
Race
(People from minority ethnic backgrounds, people of different nationalities).
Potential impact/s to consider:
- People who come into contact with local authority adult social care services, who face racism in accessing or using social care services. This includes people with needs connected to ethnicity, such as people who use health and care services who may not speak English as their first language.
- Any equity issues for people from ethnic minority backgrounds who work in health and social care services, such as workplace racism, which might have an impact on the quality of care. This includes employees at risk of modern slavery and international workers.
Religion or belief
(People with different religions and/or beliefs or no belief).
Potential impact/s to consider:
- People who come into contact with local authority adult social care services, who have additional cultural needs because of their religion or belief, or who may face discrimination because of their religion or belief.
- Any equity issues for people with different religions or beliefs who work in health and social care services, which might have an impact on the quality of care.
Sex
(Either male or female, or a group such as women or girls, men or boys).
Potential impact/s to consider:
- Ensuring services meet the needs of both men and women, unless they are a single-sex or separate-sex service
- Any equity issues for women or for men who work in adult social care services, which might have an impact on the quality of care.
Sexual orientation
(People who are heterosexual, gay, lesbian or bisexual).
Potential impact/s to consider:
- People who come into contact with local authority adult social care services, who have additional vulnerabilities or needs because of their sexual orientation, or who may face discrimination because of their sexual orientation.
- Any equity issues relating to sexual orientation for people who work in adult social care services, which might have an impact on the quality of care.
Carers
(People with caring responsibilities).
Potential impact/s to consider:
- People who come into contact with local authority adult social care services, who have additional needs because of their caring responsibilities.
Socio-economic
(People from lower socio-economic backgrounds).
Potential impact/s to consider:
- People who come into contact with local authority adult social care services, who have additional vulnerabilities or needs because of their socio-economic background.
- Any equity issues relating to socio-economic background of people who work in adult social care services, which might have an impact on the quality of care. Financial assessments are carried out by local authorities, in accordance with their Care Act (2014) duties, to determine the possible financial contribution the local authority will make to a person’s care and support. It is important to assess the impact of any decisions about our assessment approach that relate to socio-economic position and/or background, which could have an impact on fairness for local authorities in different areas.
- We also need to consider the impact of any decisions about our assessment approach which could affect people living in local authority areas where there are different local socio-economic profiles e.g. hidden areas of deprivation.
Intersectionality
(Include any other relevant information relating to the intersection of any of these protected groups and any other cross-cutting issues).
Potential impact/s to consider:
- People who come into contact with local authority adult social care services, who have additional vulnerabilities or needs because of the intersection of protected characteristics or other cross-cutting issues.
Wider issues of inequalities
(Consider health inequalities, inclusion health groups, cross-cutting issues).
Potential impact/s to consider:
- People who come into contact with local authority adult social care services, who have additional vulnerabilities or needs because of wider issues of inequality. For example, access to good quality housing, education and transport, green space and clean air.
- Under Part 1 of The Care Act (2014) local authorities must address inequalities and wider determinants of health in their local response and provision of care and support. It is important to assess the impact of any decisions about our assessment approach that relate to people who encounter inequalities in experience and outcomes.
Human rights
(Consider where there is a human rights implication).
Potential impact to consider:
We need to ensure that the assessment framework for local authorities supports our commitment to promoting human rights and preventing human rights breaches.
Any proposed changes to the assessment framework for local authorities also need to ensure that we can identify and assess risks to the human rights of people who use social care services or employees in a service, and good practice within a service in protecting and promoting human rights.
CQC has duties as part of the UK National Preventive Mechanism, when we are visiting or inspecting services where people are deprived of their liberty or detained. Though this does not include Local Authority Assessments, we may use information from our NPM duties to discuss relevant issues with Local Authorities about the human rights of people deprived of their liberty.
Action plan
1. Engage and involve
Issue identified
We are committed to ensuring that we consider the experiences of people, including unpaid carers, who are most likely to have poor access, experiences or outcomes from care – in our engagement.
Actions
- Undertake a range of engagement opportunities and outreach methods to ensure that the approach to engagement and co-production proactively includes hearing from disabled people and unpaid carers (completed).
- Include a specific question about how we can improve the focus on people and unpaid carers in our assessments and reports and ask if the existing quality statements capture priorities for people (completed).
Progress
- We held a series of online workshops with national voluntary sector organisations representing people who use services. These included organisations specifically representing carers and people with disabilities.
- We held online focus groups with unpaid carers and with people with a learning disability through Choice Support. We asked about their experiences of accessing support from their local authority and asked specific questions about how we can emphasis their voice and experiences in our assessments.
- We asked people with a learning disability to feedback on an easy read version of our assessment reports to inform development of a template for this.
- We reviewed engagement responses to ensure feedback about the equality issues, for example the experiences of people using services and in particular unpaid carers informed development of the assessment approach.
- The online workshops and focus groups were small scale and focussed. We specifically wanted to hear from people with experience as unpaid carers and people with a learning disability and we worked with Choice Support for this.
Next actions
- Establish an engagement plan for groups whose voices are seldom heard for future development of assessment frameworks and methodology, including input through VCSE partners and unpaid carers.
- Develop our approach to ensure our engagement approach specifically includes a wider diversity of voices from minoritised and under-represented communities, in line with the Race and Health Observatory’s anti-racism principles and CQC’s approach to becoming an anti-racist organisation. For example we will:
- explore how to engage specifically with organisations representing Black and minority ethnic people, including unpaid carers
- begin to gather and report participation in terms of representation (e.g. by protected characteristics)
- continue to include a specific question about potential equality issues and impacts in future engagement, co-production and evaluation.
Actions to be completed by
Engagement Senior Management Team (actions 1 and 2 completed by April 2026, next actions to align with programme).
2. Accessibility and language
Issue identified
We need to ensure that our reports become more accessible and both reports and framework place more emphasis on the experiences and outcomes for people including unpaid carers.
We need to ensure our reports, assessment framework and its supporting guidance meets CQC’s accessibility standards and writing guidance on using clear, plain English language and terminology.
Action
- Ensure that all outputs follow CQC’s accessibility standards and internal guidance and terminology for people in protected characteristic groups and others. When a specific population group is mentioned but others are not, ensure there is a rationale for including it (ongoing action).
- Be clear in the assessment framework when we are referring to people’s experiences and when we are referring to feedback from unpaid carers, avoid grouping together (completed).
- Further strengthen how people’s experiences, are represented in our reports, including unpaid carers (completed).
Progress
Our updated approach to assessing local authorities now gives more emphasis and prominence to issues relating to unpaid carers in our assessment activity, judgements and reporting.
Next action
- Consider how to develop our approach to improve accessibility of assessment reports and guidance with people who might need to access them. For example by using easy-read and other approaches (started).
- Consider how to test and evaluate reports and guidance with different groups of people who will be using them (ongoing).
Action to be completed by
Deputy Director for Local Authority Adult Social Care and Local Authority Policy and Engagement Senior Management Team, by April 2026.
3. Name and amplify
Issue identified
We are committed to ensuring that we consider the experiences of people, including unpaid carers, who are most likely to have poor access, experiences or outcomes from care in our assessments.
We need to ensure the assessment approach supports us in tackling epistemic injustice, which can arise if we pay more attention to evidence from local authorities and service leaders rather than people who use services and frontline staff.
We need to ensure that we can use the assessment approach to identify and name racism and other discrimination where we find it, to ensure that we address it through our assessment activities.
Action
- Ensure that evidence gathered in assessments, including from people’s experiences and from unpaid carers, has appropriate weight within the assessment framework. This is to support us in tackling epistemic injustice (completed).
- Strengthen how the assessment framework helps local authorities identify and respond to equality issues by providing clear expectations through introduction of rating characteristics (completed).
- Strengthen how the assessment approach helps assessment teams reach and involve unpaid carers during the assessment process (ongoing).
Action to be completed by
Deputy Director for Adult Social Care and Local Authority Policy, by April 2026.
4. Assure
Issue identified
We need to ensure consistency and confidence that equity and human rights are considered in the assessment process.
Action
- Ensure that the framework continues to tackle inequalities in outcomes, experience and access (completed).
- Ensure that the equity remains a golden thread and a priority area of focus in assessments, including within the quality statements and rating characteristics (completed).
- Consider opportunities to strengthen focus on people’s voice equity and human rights in the assessment framework (completed)
- Develop the assessment framework to give greater emphasis to evidence from people’s experience including unpaid carers (completed)
Progress
Our updated approach to assessing local authorities continues to include consideration of equality and human rights in our assessment activity, judgements and reporting.
Next action
Consider what support is needed for assessment teams to assess equality and human rights and how to evaluate (started).
Action to be completed by
Deputy Director for Adult Social Care and Local Authority Policy, by April 2026.
5. Legislation
Issue identified
We need to ensure that the framework consistently and correctly references equality and human rights legislation.
Action
Review the content of the framework to ensure that equality and human rights legislation is referenced consistently and correctly, and that we are making the appropriate linkages to enable us to take preventative action where necessary and support rights-respecting care and support (completed).
Action to be completed by
Deputy Director for Adult Social Care and Local Authority Policy, and Deputy Director for Equity and Rights, by April 2026.
Action monitoring and review
As of 31 March 2026, 11 of the 18 actions above were completed, a further 3 are ongoing actions, and 4 actions are planned or in progress.
This action plan will be further reviewed within 6 months of publication.
We also plan to update this equality impact assessment (EIA) to incorporate any relevant learning or actions arising from further engagement activities and from other relevant activity e.g. the EIA for the separate provider assessment framework consultation.
Sign-off
This equality impact assessment was signed off by Lucy Wilkinson, Deputy Director Equity and Rights, Policy and Strategy, on 8 April 2026.
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