The Care Quality Commission (CQC) has just released a significant regulatory update that may signal one of the most notable shifts in inspection methodology since the introduction of the Single Assessment Framework (SAF) in 2024.

For providers who have spent the past two years embedding quality statements, this latest development raises an important, and slightly surprising, question:

Are we moving back towards a KLOE-style approach?

What’s Changing?

Following its “Better regulation, better care” consultation, the CQC has confirmed it is moving away from a single, universal assessment framework and instead introducing sector-specific frameworks.

Four draft frameworks are now in development for:

• Adult social care
• Mental health
• Primary care and community services
• Hospitals (secondary and specialist care)

This marks a clear shift away from the “one-size-fits-all” SAF model.

The Big Shift: Quality Statements → Structured Questions (KLOE-style)

Under the new proposals:

• The 5 key questions remain unchanged:
  • Safe
  • Effective
  • Caring
  • Responsive
  • Well-led
• However, quality statements are being replaced by:

“Key lines of enquiry framed as structured questions”

This is where things get interesting.

While not explicitly labelled as KLOEs, the language and structure are unmistakably familiar. Providers who worked under the pre-2024 regime will recognise this immediately:

✔ Structured prompts
✔ Clear lines of enquiry
✔ Defined inspection focus areas

In practical terms, this is a return to a more interrogative inspection style, arguably closer to the legacy KLOE framework than the narrative-based SAF.

Reintroduction of Ratings Clarity

Another key addition is the introduction of detailed rating characteristics, describing what:

• Outstanding
• Good
• Requires Improvement
• Inadequate

look like within each sector.

This replaces the more fluid scoring approach used under SAF.

Importantly, the CQC has also confirmed it intends to remove scoring entirely, with ratings being determined directly at key question level.

What this means for providers:

• Less ambiguity in how ratings are formed
• More explicit expectations
• Greater consistency (in theory) across inspections

Why This Matters (And Why It’s a Big Deal)

This is more than just a technical update, it represents a philosophical shift in regulation.

Under SAF:

• Providers were encouraged to tell their story
• Evidence was more narrative-driven
• Quality statements required interpretation and contextualisation

Under the proposed model:

• Inspectors will likely take a more structured, question-led approach
• Evidence will need to be clearly mapped to defined lines of enquiry
• There will be less room for ambiguity

In short: inspection readiness is becoming more explicit—but also more scrutinised.

Is This Really the Return of KLOEs?

Not officially, but functionally, it’s hard to argue otherwise.

While the CQC is not using the term “KLOEs”, the move towards:

• Structured questions
• Defined rating characteristics
• Sector-specific frameworks

…strongly mirrors the pre-SAF inspection model, albeit in a modernised format.

For experienced providers, this may actually be welcome news:

• Easier to understand expectations
• Clearer inspection preparation
• More predictable outcomes

What Should Providers Be Doing Now?

Although these frameworks are still in draft stage, with pilot testing expected this summer, providers should not wait.

Recommended actions:

• Begin reviewing your governance and evidence against structured questions, not just quality statements
• Re-map your existing SAF evidence to anticipated KLOE-style prompts
• Ensure your evidence is clearly aligned to SAFE / EFFECTIVE / CARING / RESPONSIVE / WELL-LED
• Strengthen audit trails, outcomes, and demonstrable impact
• Prepare teams for more direct, question-led inspection interviews

How HLTH Compliance Can Support This Transition

This is exactly the type of regulatory shift where early adaptation creates a significant advantage.

At HLTH Compliance, we are already evolving our approach to reflect the direction of travel set by the CQC.

Mock Inspections Aligned to Emerging Frameworks

We can conduct CQC-style mock inspections that:

• Test your service against both:
  • Current Single Assessment Framework expectations
  • Emerging KLOE-style structured questions
• Simulate real inspection conditions, including:
  • Leadership interviews (Registered Manager / Nominated Individual)
  • Staff competency discussions
  • Governance and audit deep-dives
  • Service user experience sampling
• Benchmark your service across:
  • SAFE
  • EFFECTIVE
  • CARING
  • RESPONSIVE
  • WELL-LED

Providing you with a clear, inspection-style report and rating indication.

Translating Your Current Systems Into the New Model

Most providers do not need to start again—but they do need to translate what they already have.

We support providers to:

• Convert quality statement evidence → structured, inspection-ready responses
• Map policies, audits and governance systems to anticipated lines of enquiry
• Identify gaps between SAF narrative evidence and KLOE-style expectations
• Strengthen areas that are likely to come under increased scrutiny (particularly WELL-LED and governance)

Practical, Actionable Improvement Plans

Following our mock inspection, we provide:

• A targeted Quality Improvement Plan (QIP)
• Prioritised actions aligned to likely inspection focus areas
• Ongoing support to embed and evidence improvements

Ensuring you are not just compliant—but inspection-ready under the new model.

Have Your Say

The CQC is actively seeking feedback from providers and stakeholders on whether the new frameworks:

• Improve clarity and consistency
• Help providers understand expectations
• Support better quality of care
• Address inequalities effectively

This is a genuine opportunity to influence how inspections will look moving forward.

HLTH Insight

At HLTH Compliance, we see this as a course correction rather than a complete overhaul.

The SAF introduced valuable principles, but in practice, many providers found it:

• Difficult to interpret
• Inconsistent in application
• Lacking inspection clarity

This shift suggests the CQC is responding to that feedback.

The likely end state?
A hybrid model combining:

• The structure of KLOEs
• With the intent of SAF

Final Thought

The message from the CQC is clear:

Clarity, consistency, and sector relevance are back at the forefront.

Providers who proactively adapt now, rather than react later, will be in the strongest position when these frameworks go live.

Need support preparing for what’s next?
HLTH Compliance can deliver a tailored mock inspection and transition plan to ensure your service is fully aligned with the CQC’s evolving approach.

Get in touch for a complimentary consultation.