Impact assessment of policy changes

97. We accept this recommendation in principle. We acknowledge the Investigation's findings that the pursuit of Foundation Trust status distorted management capacity and priorities at Morecambe Bay. 98. In response to the failings at both Mid Staffordshire NHS Foundation Trust and University Hospitals of Morecambe Bay NHS Foundation Trust: • the Foundation Trust application process has now been significantly improved, requiring a strong focus on quality of care as well as on governance and good financial control. • The Care Quality Commission now works closely with Monitor and the NHS Trust Development Authority to share intelligence about the Trusts' performance capacity and capability. • Under the Care Quality Commission's new ratings system, NHS Trusts need an overall rating of "good" or "outstanding" to progress to the next stage of the Foundation Trust assessment process • The Care Quality Commission's new inspection model, including the development of its intelligent monitoring tool, ensures that issues of concern are picked up earlier and can be addressed. 99. The Department of Health will continue work with its Arms' Length Bodies to develop policy in partnership, and ensure that oversight and regulatory mechanisms are as effective as possible in ensuring sustainable high quality care. Formal impact assessments are and will continue to be an important part of how new policies are considered and implemented.

The Thirlwall Inquiry has noted action taken in response to this recommendation.

The DHSC Senior Review Committee (SRC) looks to include all potential impacts, including any kind of risk of a perverse incentive when evaluating the impact of policies, and there is extensive quality assurance (SRC, Chief Economist sign off).

The Department’s Impact Assessment process seeks to identify risks and uncertainties associated with proposed policy changes, following best practice guidance for impact assessments and quality assurance set out by HM Treasury in the Green Book and Aqua Book.
Impact assessment procedures have been strengthened by introducing an internal Senior Review Committee who review and quality assure all impact assessments.
Risk and resource implications are a focus throughout the process and are explicitly set out when the Department publishes impact assessments.

Department of Health response (July 2015):

Accepted in principle.

“the Foundation Trust application process has now been significantly improved, requiring a strong focus on quality of care as well as on governance and good financial control.

The Care Quality Commission now works closely with Monitor and the NHS Trust Development Authority to share intelligence about the Trusts’ performance capacity and capability.

The Care Quality Commission’s new inspection model, including the development of its intelligent monitoring tool, ensures that issues of concern are picked up earlier and can be addressed.” (p. 91)