The CQC and ESG.

So environmental sustainability is something that everyone has a greater awareness of these days and that’s no different for care providers. Everyone’s recognising their responsibilities and it’s something that’s starting to gain regulatory focus and so it’s important to take it seriously.

So under the CQC’s single assessment framework they’ve introduced a series of quality statements and one of those quality statements relates to environmental sustainability and they’ve started assessing it in NHS trusts and integrated care system assessments. They’re not yet assessing adult social care providers in relation to environmental sustainability just yet. What they’ve said is that they’ll start assessing that next year in year two of the rollout of the single assessment framework.

However, I should say at this point that at the time of recording this podcast Dr Penny Dash has just published her interim report into the effectiveness of CQC, the operational effectiveness of CQC and her findings have been that an urgent need is required for a rapid turnaround of CQC. Now her final report and recommendations are due to be published in autumn 2024 and we’re not sure at this stage what that’s going to mean for the way CQC works going forwards and what it’s going to mean for the single assessment framework, but for now it’s business as usual and the single assessment framework is the inspection regime that providers have to adhere to and one of those quality statements is environmental sustainability and as I mentioned, from next year onwards, adult social care providers are going to start being assessed in relation to that quality statement.

Yeah, so specifically so well, the quality statement, first of all, it falls under the key question of is your service well led and it states, “we understand any negative impact of our activities on the environment and we strive to make a positive contribution in reducing it and support people to do the same”. So that’s the expectations for providers that they can meet this quality statement.

Sure. So CQC are going to be assessing the steps that providers are taking to become more environmentally sustainable and as part of their assessment, they’re going to be considering how well leaders carry out certain actions and how learning and culture and values are shared with the wider staff team in relation to environmental sustainability. So CQC’s guidance says that CQC will consider how well leaders understand that climate change is a significant threat to the health of service users, staff and the wider population. So that’s the first one and they’re also going to be looking to see how well leaders empower staff to understand sustainable healthcare and how to reduce the environmental impact of healthcare activity.  Other areas that they’re going to be looking at are how well do leaders encourage a shared goal of high quality, low carbon care with a focus on health promotion and prevention, so for example how can a reduction in air pollution lead to reductions in heart disease, stroke and lung cancer. I mean, that’s just one of the examples provided, there’ll be many more that fall underneath that but I think it’s quite a good example and it helps to providers to start thinking in that kind of environmentally sustainable way.

So the CQC are also going to consider how well leaders take action to ensure that their settings are low carbon, energy efficient and use renewable energy sources where possible and they’re going to be seeing if leaders take active steps to ensure that the principles of net zero care are embedded within the planning and delivery of care. So that’s how CQC is going to be assessing providers in relation to environmental sustainability.

Yeah. So obviously things could change in autumn this year when Dr Dash publishes her final report and recommendations into CQC. It might mean that changes are made to the single assessment framework but even if that happens, I think it’s clear that there is a shift in society in general, and the healthcare sector is no different, to providers having to consider their environmental impact and measures that they have in place to be sustainable. So it is going to be an area of focus and whatever the single assessment framework is going to look like, it is something to take seriously and to start focusing on if providers haven’t already started considering it. I think it’s also important to remember that regulation 17 of the regulations applies to good governance and one of the ways to demonstrate that a provider has good governance systems within their organisation is to show that they have an environmental sustainability policy and systems in place, so it’s a way to help demonstrate compliance with that and to show that the service is well led.

So if you haven’t already started, start having a think about environmental sustainability and your strategy now because this will give you time to develop it and enhance it and give you time to embed it within your own organisation and share the culture and values to your staff members within your service and all of this is helping to demonstrate that you’re a well-led service and compliant with regulation 17. I think for providers it can feel quite daunting, especially for smaller providers. You know, we don’t have a lot of money –  how are we going to show that we’re environmentally sustainable and I think the key thing is to start small, you know, there are small steps you can take. So for example one of the things providers, and a number of providers are already doing this anyway, is switch from a paper based recording system or care planning system to an electronic one. This straightaway reduces the amount of printing and paper being used.

There’s also other ways to be energy efficient and save money as well, for example switching to energy efficient light bulbs. That’s not you know, that’s not a big change, but it shows that a provider is trying to think about the ways to be sustainable, you know, monitoring temperatures and improving insulation within buildings where it’s possible to do so and other things that providers might want to consider are installing electric vehicle chargers or food waste reduction systems.

These are just ideas but I think, you know, think outside of the box. There are many ways that you can start to show how you’re being sustainable, whatever size of organisation you are and the key thing is to just set this out in a strategy. There are lots of helpful resources online – Care England offer them, so providers definitely do have that support and assistance should they need it.

So RWK Goodman supports providers with estate management and all aspects of estate management and this includes managing energy efficiency, carbon neutrality and how to take advantage of technology and we’ve also recently undertaken a number of estate reviews for clients who are looking at ways to diversify, so for income and cost saving measures, you know, looking into alternative energy generation and energy efficient measures, so there’s definitely support out there and we’re very much willing and happy to support providers. I think from a CQC perspective as well, obviously for adult social care providers, they’re not yet being assessed under this environmental sustainability quality statement but should they be in the future, depending on what happens with the single assessment framework, you know, if they are encountering difficulties with CQC, you know, there’s a range of things we can do to support providers and you know, they can reach out and contact us.