Regulatory fees from April 2013 Consultation analysis report

Transcription

1 Regulatory fees from April 2013 Consultation analysis report March 2013 Contents Page 1. Introduction 2 2. Summary 2 3. Analysis of overall responses 2 4. Analysis of individual questions 9 Question 1 Question 2 Question 3 Question 4 Question 5 Question 6 Question 7 Question 8 Question 9 Do our strategic approach and the proposals to start implementing it address the right issues? How likely is it that our strategic approach will improve our system of fees? Do you agree with our proposal for making changes to the existing fee categories? Do you agree with our proposal to increase the fee levels for providers of single speciality services? Do you agree with our proposal to adjust the fees bandings for providers of dental services? Do you have any suggestions for how we might in future consider differentiating dental providers with one location and a single practitioner, from those with one location and multiple dental practitioners? Do you agree with our proposals to charge fees to providers of primary medical services based on the bandings and fee levels we have set out? Do you agree with our proposal for fees for independent midwives? Do you agree with our proposal to decrease the fee levels for single-handed sessional providers of mobile diagnostic services? Appendix 1 Method of analysis 32 Appendix 2 List of tables and charts 33 CQC regulatory fees from April 2013 Consultation analysis report 1

2 1. Introduction This report contains the analysis of the responses to the consultation on regulatory fees from April 2013, undertaken between 28 September and 21 December This was an open consultation with the aim of obtaining views from all stakeholders. 2. Summary Five hundred and eight responses were received. The majority of responses were from NHS general practitioners (GPs) and dentists. Their responses represent 81% of the total received. Responses from representative organisations and stakeholders provided specific constructive comments on changes and improvements. Due to the relatively small numbers of responses from some sectors, it is difficult to draw any definite conclusions on their views. Despite the low response rate from independent healthcare and adult social care providers, the few who did reply to the consultation were more likely to give a positive categorical response to the questions than GPs and dentists, but many also had suggestions and concerns. The main theme of the comments was that Fees should not be charged. This was the view of the majority of GPs. Concerns were raised that rural practices may close if fees were charged for satellite practices (mainly dentists and GPs). Non-NHS providers raised concerns that additional fees for underperforming services may make it more difficult for these services to improve. The view was that additional support to improve would also be required. Respondents offered a variety of detailed suggestions of how the fee bandings could be improved. 3. Analysis of overall responses 3.1 Overall responses The total number of responses to the consultation between 28 September 2012 and 21 December 2012 was 508. These included responses from individuals as well as representative groups and private and public sector providers. CQC regulatory fees from April 2013 Consultation analysis report 2

3 3.2 Method of response Chart 1 Method of response Post 4 s 127 Webform % of respondents completed the webform available on the CQC website. responses to FeesConsult@cqc.org.uk were 25% of the total responses received. Although only four (1%) responses were sent by post, some respondents who replied by attached their response in the form of a letter. Most of the responses received by or post were not direct responses to the questions as laid out in the webform. These responses were aligned to the most appropriate question so that they could be counted and analysed. 3.3 Responses by sectors We identified each respondent s sector either by a specific question on the webform or by the address or name of the organisation on the letter or . In some cases, this information was not given by the respondent and was recorded as not collected/stated. Chart 2 shows a breakdown of the responses by sector. Chart 2 Responses by sector CQC staff 1 Independent Midwife 1 NHS Trust Adult social care - non residential 2 7 Other 12 Independent Health care 16 Not collected/stated Adult social care - residential Representative organisation Dentist 77 NHS General Practitioner (GP) CQC regulatory fees from April 2013 Consultation analysis report 3

4 NHS GPs were the largest sector represented with 65% (332) of the total responses. The number of representative organisations who responded was 5% (26) of the total. Although they were identified as categories on the webform, no responses were received from NHS walk-in centres or urgent care centres, NHS out of hours primary care or people using health or adult social care services. Table 1 shows that the number of respondents as a percentage of each sector. Even for GPs, the percentage response based on the number of GP practices is only 4% In some cases, there was more than one response from the same GP practice. Table 1: Responses from each sector as a percentage of the total number within each sector Sector Total responses from sector Total in sector (approx number where available) NHS trust % Adult social care providers residential & nonresidential 25 12, % Percentage of sector responding Independent 16 1,351 1% healthcare Dentist 77 8,083 1% NHS general 332 7,800 4% practitioner Independent 1 N/A N/A midwife Representative 26 N/A N/A organisation CQC staff 1 2, % Other 12 N/A N/A Not collected/stated 16 N/A N/A (Note: figure for NHS GP total in sector is the number of practices not GPs) 3.4 Summary of overall answers to the closed questions Q1 Does our strategic approach and the proposals to start implementing it address the right issues? Yes 132 (26%) No 240 (47%) Comment only: 10 (2%) Not answered/not applicable 126 (25%) CQC regulatory fees from April 2013 Consultation analysis report 4

5 Q2 How likely is it that our strategic approach will improve our system of fees? Very likely 9 (2%) Quite likely 45 (9%) Don t know 114 (22%) Quite unlikely 34 (7%) Very unlikely 166 (33%) Not answered/not applicable 140 (27%) Q3 Do you agree with our proposal for making changes to the existing fee categories? Yes 84 (17%) No 267 (53%) Comment only: 17 (3%) Not answered/not applicable 140 (27%) Q4 Do you agree with our proposal to increase the fee levels for providers of single services? Yes 47 (9%) No 267 (52%) Comment only: 3 (1%) Not answered/not applicable 191 (38%) Q5 Do you agree with our proposals to adjust the fees bandings for providers of dental services? Yes 86 (17%) No 196 (38%) Comment only: 9 (2%) Not answered/not applicable 217 (43%) Q6 Do you have any suggestions for how we might in future consider differentiating dental providers with one location and a single practitioner from those with one location and multiple dental practitioners? Yes 78 (15%) No 207 (41%) Comment only: 3 (1%) Not answered/not applicable 220 (43%) Q7 Do you agree with our proposals to charge fees to providers of primary medical services based on the bandings and fee level we have set out? Yes 46 (9%) No 306 (60%) Comment only: 55 (11%) Not answered/not applicable 101 (20%) Q8 Do you agree with our proposal for fees for independent midwives? Yes 78 (15%) No 164 (32%) Comment only: 3 (1%) Not answered/not applicable 263 (52%) CQC regulatory fees from April 2013 Consultation analysis report 5

6 Q9 Do you agree with our proposal to decrease the fee levels for single-handed sessional providers of mobile diagnostic services? Yes 99 (19%) No 130 (26%) Comment only: 5 (1%) Not answered/not applicable 274 (54%) 3.5 Overall themes by sector Some individual respondents provided the same or similar comments to each question. This is useful in analysing the views against each question but further work was undertaken to identify which themes were most commonly raised across all respondents. To achieve this, an additional count was made of the number of individual responses that contained a theme. For example, if the comments for three questions from one respondent were analysed as containing the same theme, such as, Fee still too high this theme was only counted once for that individual response. The reason for this additional analysis was to reduce the chances that the same or similar comment by an individual respondent to several questions could weight one theme more than any of the other themes. Chart 3 contains the results of this analysis and shows the number of respondents out of 508 whose overall answers contain each theme. CQC regulatory fees from April 2013 Consultation analysis report 6

7 Chart 3: Themes- all respondents (508) Specialist inspectors needed Fees w ill or should be passed on to patients Fees should be incentivising e.g reductions for new practices Fees unfair for multi site providers Payment by instalment/flexible Base fees on full-time & part time w orkers or opening hours Fees are fair Fee should reflective cost of regulation Fee based on number of operatories (dental chairs/surgeons/bed numbers) Fee based on profits/turnover Fees based on organisation size The bandings need changing Fees should not be based on location Link fees and inspections to problem sectors & higher risk areas Fee scheme should be fair Proposals w ill increase costs or professionals w ill leave Fees per location (practice) Services already regulated by another body- duplication Fees should be fair across sectors Fees should be based on the number of patients/users/residents Impact on patient care Economic impact/climate Fee still too high Additional administrative burden of regulation Fees disproportionate for small organisations No fees should be charged The following tables (2, 3 & 4) show the top five themes for the sectors with 20 or more responses. The final table contains the top five themes for other sectors with less than 20 respondents each. Table 2 Top five themes NHS GPs Number GPs out of 332 highlighting theme Total % of GPs highlighting theme Percent 1 No fees should be charged % 2 Additional administrative burden of regulation 75 23% 3 Economic climate or impact 53 16% 4 Impact on patients 50 15% 5 Fees disproportionate for small organisations 49 15% CQC regulatory fees from April 2013 Consultation analysis report 7

8 Table 3 Rank Top five themes Dentists Number Dentists out of 77 highlighting theme Total =1 Fees too high 35 45% =1 Fees disproportionate for small organisations 35 45% 2 Fees should be fair across sectors 27 35% 3 Fees per location (practice) 26 34% 4 Fees based on number of operatives 14 18% % of Dentists highlighting theme Percent Table 4 Rank Top five themes Representative organisation Number Representative Organisation out of 26 highlighting theme Total % of Representative Organisation highlighting theme Percent 11 42% 1 Link fees & inspections to problem sectors & high risk areas 2 Fees should be fair across sectors 10 38% 3 No fees should be charged 9 35% 4 Economic climate or impact 7 27% =5 Fee scheme should be fair 6 23% =5 Fees should be based on the number of patients/users 6 23% Table 5 Top 5 themes other respondents (Adult social care, independent health, NHS trusts, CQC staff, independent midwife and those with sector not stated) Number of Other sectors out of 73 highlighting theme Total % of Others highlighting theme Rank Percent 1 Fees disproportionate for small organisations 15 21% 2 Link fees and inspections to problem sectors & 12 16% higher risk areas =3 Fees should be fair across sectors 11 15% =3 Economic impact/climate 11 15% =3 Fee still too high 11 15% =3 No fees should be charged 11 15% No fees should be charged was the theme of the comments from 40% of respondents although these were mainly GPs. No single theme was common to the top five themes for all sectors with 20 or more responses, for example, the Economic climate is in the top five overall and in the top five for GPs and representative organisations, but not for dentists. CQC regulatory fees from April 2013 Consultation analysis report 8

9 Even for the sectors with a smaller number of respondents, such as adult social care providers and independent healthcare Fees disproportionate for small organisations was one of the most commonly highlighted themes. Almost a third of the 16 independent healthcare sector respondents highlighted the themes of the Economic climate and Fees based on turnover/profit. 4. Analysis of individual questions 4.1 Question 1 Does our strategic approach and the proposals to start implementing it, address the right issues? Chart 4 Question 1 Overall response Yes 132 No 240 Comment only 10 Not answered/not applicable Of the 508 respondents 372 (73%) answered this question. Ten (2%) provided a comment only The remaining 126 (25%) did not answer or said that the question was not applicable to them Of the 372 who answered this question 35% (132) answered yes and 65% (240) answered no CQC regulatory fees from April 2013 Consultation analysis report 9

10 Responses by sectors to question 1 Chart 5 Question 1: Response by sector Independent Midwife CQC staff NHS Trust Adult social care - non residential Other Not collected/stated Independent health care Adult social care - residential Representative organisation Dentist NHS General Practitioner (GP) Not answered/not applicable Comment only No Yes Two hundred and fifty-four NHS GPs answered this question and a significant number (186, 73%) did not agree that the proposal addressed the right issues. Respondents from other sectors who answered this question were more evenly split between those who agreed and those who disagreed. o Dentists were almost equally split between those who said Yes (29, 48%) and those who said No (31, 52%). o Although the number of respondents from the Adult social care residential sector was low, six said yes and seven said no. Five did not answer. Representative organisations and independent healthcare organisations who gave a Yes or No response the majority agreed with the proposals (11, 73% and 5, 63% respectively) Qualitative data analysis for question 1 Table 6 Number of respondents out of 508 Percentage of respondents Rank Question 1: Top 5 themes (all respondents) 1 No fees should be charged 67 13% 2 Additional administrative burden of regulation 46 9% 3 Economic Impact/climate 29 6% 4 Services already regulated by another body- 21 4% duplication 5 Impact on patient care 20 4% CQC regulatory fees from April 2013 Consultation analysis report 10

11 In contrast to many of the comments from GPs and dentists, representative organisations, including stakeholder groups, offered useful suggestions for inclusion and improvement. Representative organisations broadly supported the strategic approach and the need to involve these groups, such as the BMA and BDA was emphasised. Some answers did not specifically relate to the question. Quotes Q1 We generally agree with the strategic approach but have concerns about some of the proposals. (Representative organisation) We are supportive of the Commission s strategic approach to fees, particularly the emphasis on transparency and partnership working with providers. We support the Commission s intention to gather more intelligence on the costs of regulation to inform fee setting (Representative organisation) We welcome and support the high level strategic direction set out in this consultation. The proposed objectives for capture what is important to our members when setting fees for providers of care. (Representative organisation) it is imperative that you have strong engagement with the sector as you begin to define the steps you will take to achieve your plan. (Representative organisation) In the most part, the strategy seems sensible in terms of charging organisations a fair proportion of the cost of work for each grouping. (Adult Social Care residential) As a provider of dental services, we are already closely regulated by the GDC. This is duplication and so the CQC fees should show this and be reduced or removed. (Dentist) Fees should be aligned with carer/service user ratio. (Adult Social Care provider non residential) providers that are struggling with compliance often find that the financial cost of extra measures required in order to achieve compliance may push them over the edge. (Independent Health Care) encourage everyone to file on line so they can cut costs. (Other) CQC should be charging the NHS Commissioning Board directly.reducing bureaucracy and cost enormously. (NHS GP) Inspections should highlight where practices succeed and excel and promote clear information on how to meet essential standards. (Representative Organisation) There are examples of providers who are altering the number of beds they register in line with their occupancy, rather than their overall capacity, to save on registration fees. (Other) CQC regulatory fees from April 2013 Consultation analysis report 11

12 4.2 Question 2 How likely is it that our strategic approach will improve our system of fees? Chart 6 Very likely Quite likely Don t know Quite unlikely Very unlikely Not ansered Of the 508 respondents 368 (72%) answered this question. One hundred and forty (28%) did not give an answer. Of the 368 respondents who answered the question: Fifty-four (15%) gave positive responses of quite or very likely. Two hundred (54%) gave a negative response of quite or very unlikely. One hundred and fourteen (31%) answered don t know. Responses by sectors to question 2 Chart 7 Question 2 Response by sector Independent Midwife CQC staff NHS Trust Adult social care - non residential Other Not collected/stated Independent health care Adult social care residential Representative organisation Dentist NHS General Practitioner (GP) Not answered Very unlikely Quite unlikely Don't know Quite likely Very likely CQC regulatory fees from April 2013 Consultation analysis report 12

13 Of the 200 negative responses 191 (96%) were from GPs or dentists. Out of the 54 positive responses 31 (57%) were from GPs and dentists. Of the other sectors who gave a response more were positive (23) than negative (9). The webform did not include an option to include comments for this question. However, those who responded by or letter did offer comments on this question. The majority of these were from representative organisations. Quotes Q2 It is very difficult to tell whether this approach will improve the system of fees. The integration of fees into the wider regulatory system certainly has potential to increase the CQC s overall efficiency, but this might be difficult to balance with the need to fully meet costs from fees alone. This is because attempts to punish or reward registrants through the fee setting mechanism will create an inherent level of uncertainty in the CQC s fee income. Our main concern with approaches of this type is the risk of destabilising poorly performing providers by applying higher fees at a point in time when they are already likely to be facing financial challenges, given that financial and quality performance issues are often closely linked. 4.3 Question 3 Do you agree with our proposal for making changes to the existing fee categories? Chart 8 Question 3 Overall response Yes 84 No 267 Comment only 17 Not answered/not applicable CQC regulatory fees from April 2013 Consultation analysis report 13

14 Of the 508 respondents, 351 (69%) answered this question. Seventeen (3%) provided a comment only. The remaining 140 (28%) did not answer or said that the question was not applicable to them. Of the 351 who answered this question 24% (84) answered yes and 76% (267) answered no. Response by sectors to question 3 Chart 9 Question 3 Response by sector Independent Midwife CQC staff NHS Trust Adult social care - non residential Other Not collected/stated Independent health care Adult social care - residential Representative organisation Dentist NHS General Practitioner (GP) Not answered/not applicable comment only No Yes In contrast to the mostly negative responses from GPs and dentists the response from other sectors, such as adult social care provider non-residential and representative organisations shows that where the question was answered more responses were positive than negative. Qualitative data analysis for question 3 Table 7 Number of respondents Percentage of total respondents (508) Rank Question 3: Top five themes (all respondents) 1 No fees should be charged 90 18% 2 Fee still too high 35 7% 3 Economic impact/climate 30 6% 4 Additional administrative burden of regulation 29 6% =5 Fees should be fair across sectors 21 4% =5 Fees disproportionate for small organisations 21 4% CQC regulatory fees from April 2013 Consultation analysis report 14

15 Only 7 respondents whose comments related to the theme of No fees should be charged were not GPs. Only one of the 21 respondents who felt that Fees should be fair across sectors was a GP. The comments were varied with some respondents saying that some of the changes made the system simpler and fairer and others arguing for different bandings or that fees should be comparable with another sectors. Some respondents, particularly those from adult social care, gave detailed suggestions on how the fee bandings should operate. Quotes Q3 We believe that these will better segregate groups of providers to reflect appropriate levels of regulatory costs. (Representative Organisation) We agree provided that this will not result in fees increasing, but lead to the rationalisation of the inspection approach. (Representative Organisation) I am unsure why hospices need to go in the category for care homes as that is not what we do. Surely there are enough hospices to have their own category and to be treated independently. The majority of hospices are charitable and on the whole cost the CQC very little work. We need to ensure at all times that charitable monies are being used in the right way and not to help to shore up other costs. (Other) Small rural practices with small list sizes will be disproportionately affected. (GP) I think there should be a lower band of less than 3000 with a lower fee. (GP) a sliding scale depending on the number of employees and office staff. (Adult Social Care non-residential) The stepped increase in charges vs beds doesn t appear to have been addressed. (Adult Social Care- residential) Single handed practitioners GPs or GDPs, midwifes etc. should no be charged as they are already regulated. (GP) It does seem a little imbalanced when homes that are compliant have to subsidise homes that are not. (Adult Social Care - residential) The change of names of categories is simpler. (Independent health Care) I think this should be per location even at higher numbers. (Dentist) It is just not fair to expect a single handed practitioner to pay the same as a multipractitioner practice. (Dentist) CQC regulatory fees from April 2013 Consultation analysis report 15

16 4.4 Consultation question 4 Do you agree with our proposal to increase the fee levels for providers of single speciality services? Chart 10 Yes No Comment only Not answered/not applicable Of the 508 respondents 314 (62%) answered this question. Three (0.5%) provided a comment only. The remaining 191 (37.5%) did not answer or said that the question was not applicable to them. Of the 314 who answered this question 15% (47) answered yes and 85% (267) answered no. Responses by sectors to question 4 Chart 11 Independent Midwife CQC staff NHS Trust Adult social care - non residential Other Not collected/stated Independent health care Adult social care residential Representative organisation Dentist NHS General Practitioner (GP) Not answered/not applicable comment only No Yes CQC regulatory fees from April 2013 Consultation analysis report 16

17 Only 4 respondents could be identified from their response as being a single speciality service and only one agreed with the proposal. The lower number of responses reflects the speciality area. However, the high number of no responses may be due to lack of knowledge of this sector and in fact some comments suggested that a don t know option should be included. Qualitative data analysis for question 4 Table 8 Number of respondents Percentage of total respondents (508) Rank Question 4: Top five themes (all respondents) 1 No fees should be charged 39 8% 2 Fee still too high 20 4% 3 Economic impact/climate 11 2% =4 Fees disproportionate for small organisations 8 Less than 2% =4 Impact on patient care 8 Less than 2% The themes identified reflect the responses from the largest sectors, GPs and dentists. Sector specific response single speciality services There were four respondents who could be identified as provider of single speciality services. The themes highlighted in their comments for this question were: Services regulated by another body. Fees should be fair across sectors. Impact on patient care. Fee still too high. Fees disproportionate for small organisations. Fee based on profit/turnover. Across all questions, in addition to the themes above, the responses from these providers included suggestions that fees should be based on organisation size or number of full and part time employees or opening hours. Reference was also made to the impact of the economic climate. CQC regulatory fees from April 2013 Consultation analysis report 17

18 Quotes Q4 As a large Provider with some sixteen plus locations this new fee structure would incur an additional annual cost a significant rise from the previous annual fee. The impact of this in the current financial climate is burdensome and whilst we support the overall reform of the fee methodology and welcome the potential for high performers avoiding the cost of regulation we ask that a review be undertaken (Independent Health Care) a number of independent sector providers are affected by the increase for single speciality providers change providers are experiencing the impact of the economic challenges to their finances and some of those that fall into the single speciality services more so For the subsequent years when the fees model will be better reflecting cost and regulatory model would it not be fairer to wait until 2014 to make this shift? (Other) Currently our company employs 2 full-time staff, dialysing no more than 3 patients at a time.... We find it hard to understand how a company on a single site such as ours should be asked to pay 2, to be registered with yourselves, whilst other operators carrying out a huge amount of business on a single site would only be charged the same amount for their registration. Whilst realising that the CQC does not differentiate between businesses based on turnover or profit, possibly the number of employees should be a consideration. We in effect will be charged 1, per fulltime employee to provide a service that is already under pressure due to inflated costs and tariff reductions. We have, and always hope to have a good working relationship with the CQC and their inspectorate, however this proposed 33% increase is extremely hard to accept under the current financial climate. (Independent Health Care) Fee should be based as a percentage of income in these harsh economic times. (Independent Health Care) Perhaps a fee based on turnover would be more appropriate. (Independent Health Care) We are already regulated and pay fees to the HFEA so your services overlap with another government organisation. (Independent Health Care) it seems unfair to single out this service for the coming year given the financial difficulties some of these organisations are facing. (Other) I am struggling to understand why slimming clinics are being asked to pay between two and three times as much as dental practices and GP surgeries. (Representative organisations) My annual income as a single speciality provider is likely to be less than 1500 this year i.e. less than the CQC fee for registration. Fees must reflect turnover and have a lower minimum payment level to avoid driving people like me out of business. (Independent Health Care) If only providing single speciality services it should be cheaper to monitor not more costly. (GP) CQC regulatory fees from April 2013 Consultation analysis report 18

19 4.5 Consultation question 5 Do you agree with our proposal to adjust the fees bandings for providers of dental services? Chart 12 Question 5 Overall response Yes 86 No 196 comment only 9 Not answered/not applicable 217 Of the 508 respondents 282 (55%) answered this question. Nine (2%) provided a comment only. The remaining 217 (43%) did not answer or said that the question was not applicable to them. Of the 282 who answered this question 30% (86) answered yes and 70% (196) answered no. Responses by sector to question 5 Chart Question 5 Response by sector Independent Midwife CQC staff NHS Trust Adult social care - non residential Other Not collected/stated Independent health care Adult social care - residential Representative organisation Dentist NHS General Practitioner (GP) Not answered/not applicable Comment only No Yes CQC regulatory fees from April 2013 Consultation analysis report 19

20 Chart 14 Dentist only response to Q Yes No Comment only Not answered/not applicable 2 8 Of the 77 dentists who responded to the consultation, 67 (87%) answered this question. Two gave a comment only. The remaining eight (10%) did not answer. Of the 67 dentists who answered this question, 43% (29) answered yes and 57% (38) answered no. Among some sectors (although small numbers) more respondents agreed with the proposal than did not, for example, Independent Health Care and Adult Social Care residential. Neither of the two representative organisations who answered agreed with the proposal. A higher percentage of dentists who answered this question agreed with the proposal (43%) compared to the percentage across all sectors (30%) who answered this question. Qualitative data analysis for question 5 Table 9 shows the top five themes for all respondents compared with the number of Dentists whose comments reflected the same themes. Table 9 Total all respondents Rank Question 5: Top five themes (all respondents) 1 Fees disproportionate for small organisations No fees should be charged Fees per location (practice) Fee still too high Fees should be fair across sectors 13 9 Total for Dentist for this theme CQC regulatory fees from April 2013 Consultation analysis report 20

21 Table 10 shows the top five themes for dentists for this question compared with the number of all respondents whose comments reflected this theme. Table 10 Question 5: Top 5 themes Dentist Dentists only 1 Fees disproportionate for small organisations Fees per location (practice) Fee still too high Fees should be fair across sectors 9 13 =5 Economic impact/climate 5 11 =5 Link fees and inspection to problem sectors/high risk areas 5 7 All respondents For this question only dentists and GPs felt that fees should not be charged. Some comments from dentists regarding fees being fair across sectors referred to the differences in calculating GPs and dentist fees. The two representative organisations who answered gave detailed suggestions and changes that could be made. There views centred around the themes of: o Fees being disproportionate for small organisations o Fees should be fair across sectors o Fees per location o Services already regulated o Linking fees to high risk areas and cost of regulation. CQC regulatory fees from April 2013 Consultation analysis report 21

22 Quotes Q5 If CQC is to provide value for money and equity, and still charge fees, then fees should be representative of cost. Inspecting a location, as CQC suggests, costs a given amount and, as we have explained, there is no reason for organisations with many locations to receive a discount as the inspection and the cost for each practice should be the same; there is no guarantee of uniformity in compliance across a provider s group of practices. (Representative organisation)...level of monitoring should be commensurate with the level of risk. Practice visits could be more focused which would lead to reduced cost. CQC could save money by reducing the number of visits to those practices which are seem to be very robust in their compliance. (Representative organisation) Location should be the significant factor. (Dentist) Should be same fee per site. (Dentist) Base it on turnover, not the number of sites. (Dentist) Reduce the inspection frequency to say every three or five years. (Dentist) I ve paid twice for CQC registration and still not been inspected (Dentist) Why base GPs on the number of patients but not dentists? (Dentist) Increase in fees for dental providers should be limited to dentists with NHS contracts as their income is considerably more than private dentists (Dentist) 4.6 Consultation question 6 Do you have any suggestions for how we might consider in future differentiating dental providers with one location and a single practitioner from those with one location and multiple dental practitioners? Chart 15 Question 6: Overall response Yes 78 No 207 comment only 3 Not answered/not applicable CQC regulatory fees from April 2013 Consultation analysis report 22

23 Of the 508 respondents, 285 (56%) answered this question. Three provided a comment only. 43% (220) did not answer or said that the question was not applicable. Of the 285 who answered this question, 27% (78) answered yes and 73% (207) answered no. Of the 285 who answered this question, 64 (22%) were dentists. Although 52 dentists answered Yes to this question a total of 54 comments were given by this sector (some said no but still gave a comment). One representative organisation gave a comment. Qualitative data analysis for question 6 Table 11 shows the top five themes for this question for all respondents compared with the number of dentists whose comments reflected the same themes. Table 11 Rank Question 6:Top 5 themes (all respondents) All respondents 1 Fees based on number of operatives (dental chairs) =2 Fees disproportionate for small organisations =2 Fees per location (practice) Fee still to high No fee should be charged 12 1 Dentists only Table 12 shows the top five themes for this question for the comments from dentists compared with the number of all respondents whose comments reflected the same themes. Table 12 Rank Question 6: Top 5 themes Dentists Number of Dentists =1 Fees based on number of operatives (dental chairs) =1 Fees disproportionate for small organisations Fees per location (practice) Fees still too high Base fees on full-time & part-time workers or opening hours 7 7 All respondents The top four themes identified by dentists were the same as those for all respondents but this is because dentists made most comments. The theme ranked as fifth by dentists (7) was Base fees on full-time & part-time workers or opening hours. No other sector s responses reflected this theme in their responses to this question. Of the 12 responses where the theme was No fee should be charged, nine of the respondents were GPs. CQC regulatory fees from April 2013 Consultation analysis report 23

24 Quotes Q6 The proposed fee banding, which charges different amounts for multiple locations, each of which requires inspection and the same scrutiny, should be changed We consider that there would be merit in investigating a system such as that adopted by RQIA in Northern Ireland, which is based on the number of chairs in a practice. (Representative organisation) Bandings could be grouped fees starting at 1-3 practioners, 4-6, 7+ (Dentist) There should be a set charge per active surgery i.e dental chair in a room at any location. (Dentist) Ask the question how many full time/ part time practitioners are there working at the practice. (Dentist) All practices should be charged a similar amount, with a discount on small practices, like you do for doctors. (Dentist) Single locations with 2-3 surgery could be charged with a base fee of 400 and single locations with 4+ surgeries will require regulation with a fee of 1,200 applicable. (Dentist) List size as per medical practices. (GP) Use list size, number of patients seen, number of appointments offered or income as the measure to decide level of charge. (GP) It is exactly the same issue as the bandings for single speciality services CQC does not propose to differentiate the fee structure to consider the size of the location/number of staff etc of either dental or other services. (GP) 4.7 Consultation question 7 Do you agree with our proposal to charge fees to providers of primary medical services based on the bandings and fee levels? Chart 16 Question 7 Overall response Yes 46 No 306 comment only 55 Not answered/not applicable CQC regulatory fees from April 2013 Consultation analysis report 24

25 Of the total 508 respondents 352 (69%) answered this question. Fifty-five (11%) gave a comment only. The remaining 101 (20%) not answer or said that the question was not applicable to them. Of the 352 who answered this question 13% (46) answered yes and 87% (306) answered no. Responses by sector to question 7 Chart 17 Question 7: Response by sector Independent Midwife CQC staff NHS Trust Adult social care - non residential Other Not collected/stated Independent health care Adult social care - residential Representative organisation Dentist NHS General Practitioner (GP) Not answered/not applicable comment only No Yes Only 12 (3%) of GPs who answered this question agreed with the proposals. 75% (266) of those who answered this question were GPs, although 44 of the 55 who provided a comment only were from this sector. All sectors except Adult Social Care residential disagreed with the proposal. Qualitative data analysis for question 7 Table 13 shows the top five themes for GPs compared with the number of all respondents whose comments reflected the same themes. (The top five themes were the same for GPs and all respondent for this question). CQC regulatory fees from April 2013 Consultation analysis report 25

26 Table 13 Rank Question 7: Top 5 themes - GPs GP s All respondents 1 No fee should be charged Fees should be based on number of patients Fees disproportionate for small organisations Additional administrative burden of regulation Impact on patient care The top five themes in the comments for this question are the same for all respondents and GPs. The views of the eight representative organisations that made a comment about this question covered the same themes as those raised by GPs. Quotes Q7 We agree with the consultation that a hybrid model that uses both location numbers and list size provides the best way of utilising the advantages of both models, while minimising the disadvantages of both. We do have some concerns, however. Firstly, there is an anomaly in the proposed charging structure, in that a provider with two locations but with a total population of less than 5000 will pay 100 more than two separate small providers with one location each. (Representative organisation) The College believes that, as the CQC is a body working on behalf of the Government, it is for the Government to contribute to its running costs. However, if the fees are to be charged the proposed banding looks reasonable. The other point we would like to make is that we believe the CQC should have an objective to reduce the burden of inspection where appropriate. (Representative organisation) Again, a huge single site multi-gp practice which offers many additional services should be charged more than a single site, single GP practice. (GP) Regarding the fees for primary care services these do appear rather modest (Other) CQC regulatory fees from April 2013 Consultation analysis report 26

27 Quotes Q7 continued Not appropriate, it doesn t differientiate between large and small organisations fairly (GP) It is not appropriate for any provider to pay for the CQC. If the government want it they should pay. (GP) You currently propose charging practices with more than one site a much larger fee than a practice on a single site with the same number of patients. Under the national GMS contract, a practice with more than one site is still paid the same income as a practice with a single site since payment is based on the number of registered patients. It is, however, much more expensive to run two sites since the practice cannot benefit from economies of scale, always needs to purchase two of everything etc. It would, therefore, seem more equitable to charge based purely on list size not on number of operating sites. (GP) I fundamentally disagree with medical and dental sectors for regulation in addition to the other regulators we also pay. (Dentist) Drs are not being charged enough either that or dental practices are being scandalously overcharged. (Dentist) we feel it would be unfair to penalise practices with branch surgeries. (GP) My view is that the combined location/list size approach is probably the fairest way of going this. (GP) Option one based on registered list size. (GP) We prefer option 3. (GP) I don t feel that providers should have to pay a fee. (GP) Any capitation should be based on weighting and not registered lists as these are more proportionate to activity and income. (GP) CQC regulatory fees from April 2013 Consultation analysis report 27

28 4.8 Consultation question 8 Do you agree with our proposal for fees for independent midwives? Chart 18 Question 8 Overall response Yes 78 No 164 Comment only 3 Not answered/not applicable Of the 508 respondents, 242 (48%) answered this question. Three gave a comment only. The remaining 263 (52%) did not answer or said the question was not applicable. Of the 242 who answered the question 32% (78) answered yes and 68% (164) answered no. Response by sector to question 8 Chart 19 Question 8 Response by sector Independent Midwife CQC staff NHS Trust Adult social care - non residential Other Not collected/stated Independent health care Adult social care - residential Representative organisation Dentist NHS General Practitioner (GP) Not answered/not applicable comment only No Yes CQC regulatory fees from April 2013 Consultation analysis report 28

29 Only 1 respondent identified themselves as an independent midwife and they did not agree with the proposal. Within other sectors, apart from GPs, more respondents who answered the question were in favour of the proposal than were against. Qualitative data analysis for question 8 Table 14 Rank Question 8: Top 3 themes (all respondents) Number of respondents 1 Proposals will increase costs or professionals will leave 4 2 Fee still too high 3 3 Fees should be fair across sectors 2 The themes highlighted in the response to question 8 by the independent midwife were: Proposals will increase costs or professionals will leave. Additional administrative burden Fees should be fair across sectors Base fees on full-time or part-time workers or opening hours A response was also received from a representative organisation who commented, among other things, on the difference between an independent midwife and a single specialty services. Quotes Here the same happens as to single handed practitioners. The midwife is regulated by her body. Your one size fits all approach of paperwork is ridiculous and laughable and will push many excellent providers to consider if they want to continue their work. It has taken us months to complete the paperwork and the midwives will have to do it all by themselves or fork out money in addition to the 800. How can you charge a midwife more than a GP or the same as a dentist anyhow? Do you have any idea of income, in particular of someone works parttime? (Independent midwife) The implementation of the EU Directive requiring all healthcare professionals to carry Professional Indemnity Insurance (PII) means independent midwives working as self employed professionals will no longer be able to exist. Commercial insurance premiums, if they indeed existed, are estimated to be from 2-10 x a midwife s net income which clearly makes it impossible.. We agree independent midwives working in this way fit into the Healthcare: Community healthcare category but are concerned about the disparity in fees compared with both NHS and independent doctors. Midwives earn significantly less than their medical colleagues but it is proposed will pay the same CQC fees as independent doctors which are significantly more than NHS GP practices (Primary Medical care). (Representative organisation) CQC regulatory fees from April 2013 Consultation analysis report 29

30 Quotes continued While we accept the need for the CQC to recover its costs through the fees it charges independent midwives, we do have serious concerns that the fees may be too high for many independent midwives the CQC needs to be explicit about the difference between independent midwives and single specialty services. We understand that for many independent midwives the only way to attain indemnity insurance will be to work together in some formal arrangement. As such, some independent midwives may be more appropriately defined as single specialty providers. (Representative organisation) They seem excessive compared for example to PMS. How much money do you think these practitioners are making? Surely fees should be directly proportional to turnover, end of story? (Independent Health Care) Any fee will likely cause midwives to leave the profession. (GP) Fees should be lower, their huge professional indemnity costs is already close to pricing them out of the market CQC fees either inflate the cost of healthcare or depress take home pay neither is acceptable. (Dentist) 4.9 Consultation question 9 Do you agree with our proposal to decrease the fee levels for single handed sessional providers of mobile diagnostic services? Overall response to question 9 Chart 20 Question 9 Overall response Yes 99 No 130 comment only 5 Not answered/not applicable Of the 508 respondents, 229 (45%) answered this question. Five (1%) gave a comment only. The remaining 274 (54%) did not answer or the question was not applicable. Of the 229 who answered this question, 43% (99) answered yes and 57% (130) answered no. CQC regulatory fees from April 2013 Consultation analysis report 30

31 Response by sector to question 9 Chart 21 Question 9 Response by sector Independent Midwife CQC staff NHS Trust Adult social care - non residential Other Not collected/stated Independent health care Adult social care - residential Representative organisation Dentist NHS General Practitioner (GP) Not answered/not applicable Comment only No Yes No respondents identified themselves as being from this sector. Within other sectors, apart from GPs, more respondents were in favour of the proposal than were against it. Qualitative data analysis for question 9 Table 15 Rank Question 9: Top 3 themes (all respondents) All respondents 1 No fees should be charged 12 2 Fees should be fair across sectors 5 =3 Fee still too high 3 =3 Impact on patient care 3 There was agreement from a representative organisation for a reduction in fees. CQC regulatory fees from April 2013 Consultation analysis report 31

32 Quotes agrees with the reduction of fees for some of the very small diagnostic services referred to in the consultation. (Representative organisation) Why should Mobile services be any different from single location I agree with single handed single location diagnostic providers as this could describe some of our activity. Mobile should be the same. (Independent health care) The fee levels are very high for this service, however, a non-mobile service at a clinic may not have the turnover of other health care providers and the fee of 1500 is a tax on the business. (Independent Health Care) Should be no fee at all. (GP) Not fair to decrease fees to some practitioners while introducing fees for GPs. (GP) CQC regulatory fees from April 2013 Consultation analysis report 32

33 Appendix A: Method of analysis The analysis was undertaken by the Analysis Development team within the Intelligence Directorate at CQC. Responses were received by three methods: Webform submissions downloaded into a csv file on a weekly basis. s highlighted within a shared inbox for inclusion in the analysis. Scanned postal replies collected from a shared folder. The responses were copied or entered on to an Excel spreadsheet for analysis. The spreadsheet contained: The raw data. Summary of responses by method and source. A summary of the themes arising from the response. Charts derived from the raw data to illustrate the findings. The responses were analysed as follows: All responses to the consultation were collated, logged and read in their entirety. Blank webforms where no comments or answers to closed questions were given were not included in the analysis. The initial webform did not request details of sector therefore allocation of the sector for these responses was established from comments provided. A sector could not be provided in some cases. In the case of postal and responses where responses did not clearly indicate which question their comments related to, these were allocated to the most appropriate question. The comments were grouped into themes and analysed in two ways: o Counting the number of comments containing each theme against each question to establish the most common themes per question. o Counting the number of respondents (individual) who highlighted a particular theme within their overall response. For example, if the comments to three questions from one respondent were regarding the theme of Impact on patient care this theme was only counted once for the individual response. CQC regulatory fees from April 2013 Consultation analysis report 33