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Applies to: EnglandCrisis and recovery

Where do I start after a CQC Requires Improvement rating?

By Melissa MeakinPublished 7 min read

A china cup of tea on a saucer beside a closed notebook on a wooden table near a bright window.
Image: William Finn

What does a Requires Improvement rating actually mean?

CQC's own definition is short. On its ratings page, Requires Improvement means the service is not performing as well as it should and CQC has told the service how it must improve. That second half matters more than the label. The report is a list of directions, and you already hold it.

CQC also gives a rating for each of the 5 key questions, and newer reports carry a percentage score. Requires Improvement covers 39 to 62%, and Good starts at 63%. So a service at the top of that band may be closer to Good than the headline suggests, and each of the 5 key questions has its own rating, so look at those too. Read the scores before you decide how far you have to travel.

A disappointing rating is a starting point. It describes the service at the time of the assessment, not what it can become.

What has to happen in the first few weeks?

Some of this runs to the regulator's clock, and it pays to know which deadlines are fixed before you plan anything else.

What Time limit What it is for
Factual accuracy check 10 working days from the email with your draft report Correcting facts and adding evidence that existed at the time of the assessment
Rating process review Within 15 working days of the rating being published Asking CQC to check it followed its own process, not to argue with its judgement
Displaying the rating No later than 21 calendar days after publication Posters at your premises and the rating on any website that describes the service
Written report under Regulation 17 (only if CQC asks) No later than 28 days, beginning on the day after the request arrives Showing CQC how you assess, monitor and improve quality and safety, when it asks

The display rule is easy to get wrong. CQC's guidance on how providers must display ratings says you still need to display the rating even if you have asked for a review. It also encourages services rated Requires Improvement to show what they are doing to improve, and its posters include a space for exactly that. I would use it. Families will read the rating either way, and a plain line about what you have changed tells them you have taken it seriously.

Should I challenge the rating?

Only if there is something factual to correct, or CQC did not follow its own rating process. Factual points have to be raised while the report is still in draft. The factual accuracy guidance lets you correct errors, and add information that was missed, as long as it relates to the position at the time of the assessment. You can tell CQC about action taken since, but unless there are exceptional circumstances it will not form part of the final judgement or rating.

The rating process review is narrower still. The only ground is that CQC failed to follow its process for making rating decisions. You cannot ask for one because you disagree with the judgement or the score, and CQC says all scores and ratings can go down as well as up as a result.

So if your draft has just arrived, spend those first ten working days carefully. Check every fact, send the evidence that existed at the time, and then put your energy into the improvement work. That is the work the next assessment will look at.

Why do improvement plans so often stall?

In my view, plans stall when they are written for CQC rather than for the people who have to deliver them.

The first mistake is trying to fix everything at once. A plan with sixty actions, all due within the month, looks thorough and achieves very little. Staff cannot tell what matters most, and the manager spends every week chasing deadlines instead of watching care.

The second is confusing paperwork with change. A new policy, a new audit form and a training session can all be completed without anything changing for the person who waits too long for help at breakfast. If the report said people's experience was the problem, the evidence of improvement has to come from people's experience.

The third is leaving the team out. When staff first hear about the plan in a staff meeting, as a list of things they are doing wrong, you lose the people you most need.

How do I build a plan the team can deliver?

Start with the report itself. Read it once to take it in, then again with a pen. Mark every point where CQC says something must change, and group them by key question. You will usually find the same few themes running through several sections.

Then choose. I would pick the issues that carry real risk to people first, then the ones that sit underneath other problems. Weak governance or unclear leadership often sits underneath everything else, so fixing it early makes the rest easier.

For each priority, write down four things: what good would look like for the person receiving care, who owns it, what you will check, and when. Keep the owner to one name. Keep the check to something you can see, such as a conversation with the person, an observation, or a record that matches what they tell you.

CQC may send an Action Plan request, which tells you it considers you in breach of a regulation. Its enforcement policy explains what that involves. The report must show how you will comply with your legal obligations, and what action you are taking or propose to take. If the action plan does not satisfactorily address the issues, CQC may decide not to accept it. Failing to send the report within the set timescale is an offence, so treat the date in the request as fixed.

How do I keep the team going after a disappointing rating?

Tell them first, and tell them honestly. A rating of Requires Improvement lands hardest on the carers who turn up every day and do their best, and many will take it personally.

Separate the people from the systems. Where the findings are about oversight, records or consistency, say so plainly, so staff can see what needs to change. Then give them a part in the fix. The carer on nights often knows exactly why the evening medicines round runs late.

Celebrate small progress that you have checked. When an action is done and the check shows it worked, say so out loud. You must care to care, and that includes the people who have just read a report about their own work.

How will anyone know it is getting better?

If your governance is working, you will know before anyone else does. Regulation 17 asks providers to have effective governance, including assurance and auditing systems that assess, monitor and drive improvement in the quality and safety of the service. It also asks you to seek and act on feedback from people using the service, those acting on their behalf, staff and other stakeholders.

In practice, that means your audits should be finding the same things CQC found, and then finding them less often. If your own checks said everything was fine before the assessment, look hard at the checks before you look at anything else.

Keep a simple record each month: what you set out to change, what you checked, what you found, and what you did next. That record is your evidence. It also means that if CQC asks for a written report under Regulation 17, you are writing it from what already happens rather than from what you intend.

When is this not the answer?

An improvement plan is the wrong first step if people are at immediate risk. A serious concern about someone's welfare, staffing you cannot cover, or enforcement action already under way all come first. Deal with the risk, record what you did, and get the right help for that situation. Where legal action is involved, that help is a solicitor, not a consultant.

It is also not the answer if the rating rests on a factual error. Use the factual accuracy check for that, with evidence, inside the deadline.

And plenty of services do not need outside help at all. If your leadership team can read the report calmly, agree the priorities and check its own progress honestly, you may only need time.

Where do I start tomorrow?

Read the report again with a pen, mark every must, and choose three priorities. Put one name against each. Then book the next staff meeting around those three, not around the rating.

If you would like someone alongside you, my crisis management support helps services pull the priorities out of a report and build a plan the team can deliver, and my quality assurance audits test whether your own checks would find what CQC found. My earlier post on knowing whether your service is ready for an assessment covers how to keep the service ready every day once the plan is running. When you are ready, book some time with me and we can look at your report together.

Frequently asked questions

Can I take my rating down while I ask CQC to review it?

No. CQC's guidance says you still need to display the rating even if you have asked for a review. You may add a note explaining that you have asked for one, but the rating must still be clear and conspicuous.

Will CQC count improvements I make after the assessment?

You can tell CQC about action taken since the assessment during the factual accuracy check, and the assessor will consider it. Unless there are exceptional circumstances, it will not form part of the final judgements or ratings.

How long does a rating process review take?

CQC says it aims to complete all reviews within 50 working days. The rating stays published on its website while the review takes place.

Is an Action Plan request the same as enforcement?

CQC says an Action Plan request does not constitute an enforcement action. It does tell the provider that CQC considers it to be in breach of its legal obligations, and failing to send the report on time is an offence.

Official sources

Melissa Meakin

Melissa Meakin

Founder and Care Quality Consultant, Elvora Consulting

Former Registered Manager and current Nominated Individual, with more than 20 years in health and social care.

About Melissa

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