CQC special measures support

We know how this feels

Special measures is a long, public grind. The report is out, the rating is on your wall, and CQC is watching closer than it ever has. Some weeks it feels like every decision you make is being marked.

In our experience it gets personal, and it can drag on for years. You're explaining to families and staff why a regulator says the service isn't good enough, while trying to keep the same team motivated enough to fix it.

So here's the honest version. Special measures is serious, and CQC's guidance ends in action to cancel or restrict services that don't improve. It's also a route back. CQC's exit test is that no key question is still rated Inadequate. You don't have to reach Good to get out.

What is CQC special measures?

Special measures is CQC's regime for services providing inadequate care. CQC calls it an administrative framework for providers that are failing to comply with their legal requirements and need a higher than usual level of regulatory supervision. It's usually triggered by an Inadequate rating, rather than by an individual breach of regulations.

The CQC rates services Outstanding, Good, Requires Improvement or Inadequate using the Single Assessment Framework and its quality statements. Under CQC's published guidance, which CQC marks as under review, a service rated Inadequate overall goes into special measures. A service rated Inadequate for one key question is re-inspected first, and enters special measures if any key question is still Inadequate.

This page is general information, not legal advice.

Is special measures the same as an Inadequate rating?

No. The rating is CQC's judgement. Special measures is what CQC does with it: a time-limited period of closer supervision, with its enforcement powers ready if the service doesn't improve. CQC says it can still use those powers during the special measures period.

If your report is still in draft, or was published in the last few weeks, start with our Inadequate rating page. The first deadlines are about the report itself. This page is about the months that follow.

Just rated Inadequate? Start here

Why is special measures so serious?

Because the deadline has teeth. CQC says special measures gives providers a clear timeframe to improve, and if they don't, it is likely to seek to cancel their registration.

Enforcement can run alongside it from day one. CQC says it is likely to take enforcement action at the same time as a service goes into special measures. A Warning Notice or a Notice of Proposal can land while you're still writing the plan.

For groups, it spreads. When one of a provider's services goes into special measures, CQC says it assesses the wider impact on the quality of care in the provider's other services. CQC also says a provider in special measures may be under the close supervision of another oversight body at the same time.

There is no right of appeal against special measures. A caution on dates, too: CQC marks its adult social care special measures page as under review, and its detailed guidance dates from 2015. Check the current position with CQC.

Why has CQC put your service here?

Special measures follows a rating, and CQC describes ratings as a rounded assessment of the overall effect on people of how a service is provided. It's a judgement about how the service runs day to day.

In our experience, CQC asks one question at every stage. If this happened once with dozens of people who use your service, what stops it happening tomorrow? Special measures is CQC waiting to see whether you can answer that with evidence, consistently, for months.

That's why quick fixes don't land. A new policy proves you've written something. CQC wants to see that care has changed, and that it stays changed on an ordinary Tuesday when nobody's checking.

Why is a turnaround so hard from the inside?

Because you're fixing the service while it runs, with the team that was there when it went wrong. In our experience, registered managers often leave around now. Good staff get nervous and start looking elsewhere. Commissioners start asking about placements.

A common trap is an action plan that's a long list of new policies and training dates. It reads well in a meeting and shows CQC very little about the care people actually get.

Every week spent on the wrong priorities is a week you don't get back before the re-inspection. That's where we help. We cut through the noise, set clear priorities and bring structure, so the time goes on what CQC will actually look for.

What does CQC look for at the re-inspection?

Whether sufficient progress has been made, and whether any key question is still rated Inadequate. That's the exit test.

In our experience, the services that come out can show change over time: audits that improve month on month, care records that read differently, staff who can explain what changed and why, and leaders who spotted problems before CQC did. A folder of documents dated last week is far weaker than a trend.

Any key question CQC re-assesses can move, in either direction.

What happens if the service doesn't improve?

CQC's guidance is direct. If sufficient progress hasn't been made and any key question is still Inadequate, CQC begins action to stop the service operating, by proposing to cancel or vary the registration. It then monitors the service closely until it either closes or makes substantial and rapid improvements.

A further inspection follows within six months. If an Inadequate rating remains in any key question, CQC acts to stop or limit the service. CQC's enforcement decision tree tells its staff to consider cancelling the registration of a provider still rated Inadequate at the end of the time-limited period, unless there is good reason not to.

Carrying on a regulated activity after registration is cancelled is an offence, and CQC can prosecute it. A Notice of Proposal can still be answered, and a Notice of Decision can be appealed to the Tribunal. By then, though, you're fighting on CQC's timetable.

Why providers call HLTH

Turnaround is what we do. We deal with CQC enforcement and special measures day in, day out, with decades of collective experience across different types of enforcement action. We often work alongside your Registered Manager, Nominated Individual and leadership team, and provide interim leadership where there's a gap.

Our approach is supportive and structured. We acknowledge what CQC found, assess the root causes and fix what matters most first. We evidence every change, embed it so it holds on an ordinary Tuesday, and keep CQC and commissioners informed along the way.

Jayne Downey, our Non-Executive Clinical Director, was Director of Governance and Corporate Nursing and Nominated Individual for Salford Royal NHS Foundation Trust, an Outstanding-rated trust. She knows what good governance looks like from the top.

If CQC moves to cancel, the turnaround carries on. Our trusted legal partners, or your own solicitor, can support the formal response while we keep improving the service.

A case study

A provider with years of Good ratings behind it received a Notice of Proposal to cancel its registration. Then its Registered Manager left without notice. It called us on a Friday morning, and an experienced interim manager was in the service by the Monday while our governance team built the formal reply.

Special measures turnarounds start the same way. Somebody steady has to be in charge on the floor before any plan means much.

Read the full case study