Assessing quality and performance
How to submit factual accuracy comments
Note regarding our current approach
The way in which you receive your draft report to check the factual accuracy depends on which health or care sector you are in and the type of assessment we carry out.
- For assessments that require a rating for both the location and the service type assessed (that is, assessments of NHS acute trusts, independent health hospitals and independent health single speciality services), you will receive your draft report as an attachment to an email and you will be asked to complete the factual accuracy process using an MS Word form, which we will send to you at the same time.
- For all other assessments, we’ll email you a link so you can review the draft report online. You will be able to enter comments about factual accuracy against each section. You can also print or download it. There are some specific circumstances, when you can submit factual accuracy comments using the MS Word form, for example if you are unable to use our online process. You should discuss this with the inspector or assessor who carried out your assessment.
We’ll send the email to the appropriate registered person. If your organisation has more than one registered person, for example a nominated individual and a registered manager, each registered person will receive the email.
It’s important you make sure we have correct contact details for people who need to check the draft report when we carry out our assessment.
If you wish to raise one or more points about factual accuracy, you can:
- include comments on the MS Word form, if you are using it
- enter a comment against the relevant section of the report if you are using the online link, and upload any evidence
- email any evidence to support your comments against our quality statements if needed.
Providers are responsible for making sure that the responsible person has checked the factual accuracy of the draft report and that any factual accuracy comments have been approved and submitted.
In exceptional circumstances, you can submit factual accuracy comments using our MS Word form instead, for example if you are unable to use our online process.
Deadline for submitting comments
Once you receive our email with your draft report, you will have 10 working days from the date of the email to review the report and submit any comments about factual accuracy.
We will not extend this period unless there are exceptional circumstances. If you are unable to submit your comments before the deadline, you must tell us why immediately in writing. We will use our discretion to determine whether there are exceptional circumstances.
If there are no factual inaccuracies in the report, you can confirm that you have reviewed it. We will then be able to publish the final version.
What you can correct
There are certain types of correction you can make:
- Typographical or numerical errors or, for example, incorrect job titles.
- Information that has contributed to a judgement, but which you believe is factually inaccurate. You will need to provide supporting evidence. This must relate to the position at the time of the assessment.
- Additional information, or information that was omitted, which you think we should consider. For example, you may have further examples of exemplary practice that demonstrate real benefits for people using your service, which may support a rating of outstanding rather than good. Again, this must be relevant to the time of the assessment.
The draft report is based on evidence we collected during our assessment. You can also send us information about action you have taken since the assessment that addresses the concerns we raised with you, or which is included in the draft report. The assessor will consider any further information you send us and determine whether the report should be amended.
Unless there are exceptional circumstances, this new information will not form part of CQC’s decision around final judgements or ratings (where appropriate).
Example of possible outcomes from a factual accuracy check
During an assessment, the assessor asks to see a copy of a safety policy. A senior member of staff tells them there isn’t one. The assessor includes this information in the draft report and it is considered as part of the judgement. CQC also considers the information when deciding whether to take enforcement action against the provider.
Scenario 1:
As part of the factual accuracy check, the provider sends this policy to CQC, stating that it did exist at the time of the inspection and that they do not know why the senior member of staff told the assessor that they didn’t have one. The assessor is satisfied that the document was available at the time of assessment so includes this information in the final report and it is considered as part of the judgement. CQC also considers the information when deciding whether to take enforcement action against the provider.
Scenario 2:
As a result of the factual accuracy check, the provider tells us that they have now implemented a policy. The assessor includes this information in the final report, but does not consider it as part of the judgement. CQC also considers the information when deciding whether to take enforcement action against the provider.
The factual accuracy checking process should not be used to challenge:
- an assessment rating or score solely because you disagree with it
- how we carried out an assessment – see how to complain about CQC
- enforcement activity that we propose – see how to make a representation about proposed enforcement activity
If you need to ask us for information before you can submit factual accuracy comments, your request should be short, specific and should clearly justify why you need the information to raise a point of factual inaccuracy. You should send your request directly to your assessor, if you’re already in contact with them. Otherwise email enquiries@cqc.org.uk, quoting your assessment reference number (starts with AP) and marking it for the attention of the assessment team.
We will not release the inspector’s full notes from an inspection. We will consider requests for extracts of notes about a specific issue where this is reasonably necessary to enable you to understand the basis for a statement in the draft report that you believe is factually inaccurate (that is, if the basis of our statement is not clear from the draft report).
To protect the confidentiality of people reporting concerns to us we will not identify someone who has shared this information with us.
Requesting information from CQC describes the types of information you can ask us for.