In early 2024, the Care Quality Commission (CQC) faced a government-commissioned review by Dr Penny Dash, revealing systemic issues within England’s healthcare regulator. As a nurse and regulation consultant in the medical aesthetics sector, Tracey Jones explores how these challenges are impacting providers and what the future of regulation might hold.
What were the findings?
The findings of Dr Dash’s published review presented a stark and uncomfortable reality for the CQC, exposing critical limitations in its internal operations, the effectiveness of its assessment processes, and the capacity of the organisation to meet the demands of a rapidly evolving healthcare landscape.
Her review involved consultations with over 300 senior managers, clinicians, caregivers, and patients, in addition to staff working within the CQC itself. Nearly all the individuals interviewed expressing significant concerns about the working practices and efficiency of the CQC, with many of these concerns raised in the context of the CQC’s ongoing efforts to integrate a new provider portal.
Additionally, providers raised concerns about the Single Assessment Framework (SAF), the CQC’s regulatory platform, and its organisational structure all of which had been previously flagged by CQC staff themselves.
The CQC transformation programme
In 2021, the CQC embarked on an ambitious transformation programme to make the assessment and inspection process more straightforward and data-informed, reducing unnecessary complexity and improving consistency.
A key element of this transformation was the introduction of updated IT systems, a restructuring of operational inspection teams, and the rollout of a new regulatory model known as the Single Assessment Framework (SAF).
For providers like me, particularly in medical aesthetics, these changes were viewed as a positive step forward. The introduction of a more transparent scoring system for inspections, based on clear evidence requirements, seemed to offer both greater clarity and a fairer system of rating.
However, Dr Dash’s review revealed that, despite the CQC’s best efforts, its capacity to identify poor performance, drive improvements, and support providers effectively had significantly deteriorated.
In my own experience as a director of a regulation consultancy company, I observed the consequences of these systemic failures firsthand. Applications that once took approximately 12 weeks to process were now taking as long as 12 months, resulting in significant personal, emotional, and financial strain on clients who were desperately waiting for their CQC registration to launch new businesses. This delay was exacerbated by the inefficiencies of the CQC’s provider portal, which only added to the frustration of providers navigating an already complex regulatory environment.
In response to widespread feedback and a series of internal reviews, the CQC decided to close its existing application portal on November 18, 2024, reverting to a manual process, requiring service providers to submit their applications and supporting evidence via forms available on the CQC website.
Why the CQC needs a balanced, supportive regulatory approach for providers
While technology and automation are essential in streamlining processes, they must be implemented in a way that is reliable, efficient, and accessible to the people who depend on them.
The challenges outlined in the review offer an opportunity for the CQC to reflect on its approach and to make meaningful changes that will ultimately benefit both service providers and the patients they serve. In my view, I do not see the CQC’s purpose to solely enforce penalties, I see the regulatory body as a partner in care, an organisation that is invested in improving quality healthcare outcomes.
A true “critical friend” is someone who offers constructive feedback and guidance, helping providers like me identify areas of improvement and providing actionable steps to enhance the services I offer. In my experience, CQC inspections can be a valuable opportunity for growth. When a clinic team engage with regulation this can drive a collaborative and solution-oriented approach, fostering a culture of continuous improvement.
The future of aesthetic regulation
As the sector continues to evolve, so too must the regulators. The goal should be to create a regulatory environment that is transparent, fair, and conducive to ongoing improvement, one that strikes a balance between oversight and support. The closure of the CQC’s portal and the return to manual applications marks the beginning of a new chapter in the ongoing evolution of healthcare regulation in England. It remains to be seen whether this shift will provide the clarity, efficiency, and support that service providers need to thrive in an increasingly complex healthcare environment.
As we await further guidance on the proposed licensing scheme for aesthetic practitioners, regulation remains in a state of flux. Despite the uncertainty, one thing remains clear: I will continue to maintain my CQC registration. For me, being registered with the CQC represents the pinnacle of assurance for my patients, a commitment to high standards of care and a mark of quality that instils confidence in those seeking services at my clinic.
The challenges identified in Dr Dash’s review reflect the complex nature of healthcare regulation and the need for constant adaptation. As the CQC looks to address its shortcomings and rebuild its credibility, any future reforms must prioritise both efficiency and fairness to serve as a robust and supportive regulatory body for the health and social care sectors.
Tracey Jones began her career in 1996, training as a nurse and dedicating much of her professional life to neonatal intensive care. She later advanced to the role of clinical matron, overseeing four major departments. For the past two decades, Jones has transitioned into academia, first as a teaching fellow and then as a senior lecturer at a world-renowned university. In this capacity, she has presented at numerous UK and international conferences and has been widely published, including the release of her own academic book in 2020.
Jones is also a senior fellow of the Higher Education Academy and has contributed to the development of educational modules for NHS England and the World Health Organization.
For over 10 years, she has served as a clinical specialist advisor to the CQC and runs her own CQC-registered clinic, Blend Skin, in Cheshire, which she co-owns with her daughter, who is also a nurse.
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