Home › Governance & Inspection Readiness › Well-Led › The New CQC Assessment Framework

Last Updated: 19 July 2026 · Governance & Inspection Readiness · Well-Led

Every time CQC changes how it organises its assessment, a familiar cycle starts in adult social care services. Audit tools are rewritten. Folder structures are renamed. The governance calendar is rebuilt around new headings. Weeks of scarce management time go into the work, and at the end of it the service can present its evidence in the new language.

What often has not changed is the evidence itself. The same actions are still open, the same learning is still sitting in a file rather than on the floor, and the same concerns are still being found by the regulator rather than by leaders.

This article is about how to respond to a framework change without falling into that cycle. It is not an argument for ignoring what CQC does. It is an argument for knowing which parts of your governance are genuinely affected by an assessment change, which parts were never about the framework in the first place, and why the regulations themselves are the thing worth knowing properly.

What an assessment framework actually is

An assessment framework is how CQC organises its enquiries. It sets out the areas an inspector will look at, the evidence they will gather and the way judgements are reached. Quality Statements did this, Key Lines of Enquiry did it before them, and sector-specific KLOEs are being piloted to do it next.

What a framework is not is the law. That distinction sounds technical, but in practice it decides how much of your governance a framework change should touch.

A provider does not legally breach a Quality Statement or a Key Line of Enquiry. Where CQC identifies a regulatory breach, the provider has failed to meet one or more of the legal requirements set out in the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.

If your governance system is built around the regulations, a framework change alters how you present and index your evidence, and little else. If your governance system is built around the framework, a framework change appears to invalidate everything, because the scaffolding has been replaced.

What is changing, and what is not

CQC's move away from the current 34 Quality Statements is well advanced. Separate draft assessment frameworks have been developed for adult social care, mental health care, primary and community services, and hospitals, and those drafts are now being piloted and reviewed rather than simply consulted on.

Under the drafts being piloted, the five key questions remain: safe, effective, caring, responsive and well-led. Quality Statements are replaced by sector-specific Key Lines of Enquiry, supported by rating characteristics describing what care at each rating level may look like. The draft adult social care framework currently appears to reduce the number of assessment areas from 34 Quality Statements to approximately 24 KLOEs.

The first thing worth holding onto is that this is still being piloted. Piloting exists precisely so that what is being tested can be changed, and evaluation of the pilots can move the detail before anything is implemented. Rebuilding a governance system around a document that is actively under review is work you may have to do twice.

The second is that the five key questions survive. Safe, effective, caring, responsive and well-led have been the organising spine of CQC assessment for years, and they continue to be. A service that understands its own performance against those five questions is not starting from nothing when the sub-headings underneath them are reorganised.

Our guide to what the new CQC assessment frameworks mean for registered managers covers the structure being piloted in more detail. It is worth reading alongside this piece, because the two answer different questions: that article explains what the structure is, and this one is about how much of your governance should move in response.

The cost of chasing the framework

The cost of chasing a framework change is rarely money. It is management time, which in a busy service is a scarce resource.

A registered manager has a finite number of hours that are not consumed by staffing, incidents, families, commissioners and the day itself. Those hours are the ones available for oversight: reading records with intent, talking to staff about how something is actually working, being present when practice happens. When those hours go into relabelling, the oversight does not happen, and the service becomes less well governed while appearing to prepare for assessment.

There is a second cost, which is credibility with the team. Staff notice when systems change repeatedly without anything improving, and a team asked to learn a third set of headings in four years, with no visible change to how the service runs, learns that governance is paperwork rather than practice. That is a difficult belief to reverse later.

Remapped evidence is not stronger evidence

There is a particular risk in framework migration work, and it is worth naming plainly. The work produces something that looks like progress while leaving the substance untouched.

A remapped evidence structure looks complete. Every new heading has a folder, every folder has documents in it, nothing is empty, and the whole thing can be walked through in a meeting and presented as readiness. This is the False Assurance Problem in one of its cleanest forms: the artefact looks finished, and its completeness is doing the reassuring rather than its contents.

The questions that break it are the same questions an inspector would ask. Does the evidence in that folder show that something changed, or only that something was recorded? If a lesson is filed under the new heading, can the staff on nights describe it, and is the action attached to it closed, or closed on paper?

Mapping tells you where something is filed, but it does not tell you whether it works. Those are different questions, and only one of them is about the framework.

Start with the regulations, because they are what you are held to

If the framework is not the law, the obvious question is what is. The answer is the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and knowing them properly is the most useful thing a registered manager can do with the time that framework-chasing would otherwise consume.

What follows is not a recital of the regulations, because you can read those anywhere. It is where each one tends to come apart in real services, which is a more useful thing to know.

• Regulation 9, person-centred care. Care must be tailored to the person and based on an assessment of their needs and preferences. The care plan is rarely where this fails, because care plans are written carefully. It fails in the daily record that lists tasks completed and says nothing about the person, which is how task-based care quietly becomes recorded care.
• Regulation 10, dignity and respect. People must be treated with dignity, have their privacy respected and be supported to stay autonomous. Dignity is difficult to evidence through a policy and simple to evidence through language, which is why the words staff use in daily notes carry more weight with an inspector than any statement of values on a wall.
• Regulation 11, need for consent. Consent must be sought lawfully, with capacity assessed decision by decision and best interests decisions properly recorded. Blanket capacity assessments and a consent form signed once on admission are two recurring ways services fall short, as set out in how to avoid Regulation 11 breaches. The ground here has also moved, so read it alongside the new DoLS ruling and what CQC will expect.
• Regulation 12, safe care and treatment. Risks must be assessed and mitigated, medicines managed safely, and staff must be competent to deliver care safely. A signature on a MAR chart evidences that a box was completed rather than that a tablet was swallowed, a gap explored in when the MAR sheet says yes. The same pattern shows in reviews, where "no changes" is rarely neutral.
• Regulation 13, safeguarding from abuse. People must be protected from abuse and improper treatment, with systems that identify concerns and act on them. Every service has a signed safeguarding policy, and the question that matters is whether a member of staff would recognise a concern at three in the morning and know what to do with it, which is the subject of safeguarding: when the policy is not the practice.
• Regulation 14, nutrition and hydration. People's nutritional and hydration needs must be met, with support to eat and drink where it is needed. Food and fluid charts are among the easiest records to complete retrospectively, which makes them among the least reliable unless someone checks them against what people actually ate that day.
• Regulation 15, premises and equipment. Premises and equipment must be clean, secure, suitable and properly maintained. The serious end of this is environmental safety that has been assumed rather than checked, and what a fall from a care home window revealed about window restrictors, maintenance checks and the learning that should follow is a hard example of it. The everyday end is cleanliness and infection prevention, which an inspector assesses with their own eyes within minutes of arriving.
• Regulation 16, complaints. Complaints must be received, investigated and acted on through a system people know how to use. A low complaint count is not evidence of satisfaction, and can be evidence that people do not know how to raise something or do not believe it would change anything, which is the argument in behind every complaint is someone who did not feel heard.
• Regulation 17, good governance. Systems must assess, monitor and improve quality and safety, assess and mitigate risk, and maintain accurate records. This is the regulation that catches services delivering genuinely good care, because kindness is visible and governance is not, and Regulation 17 is a common reason a well-regarded service is still rated inadequate for well-led.
• Regulation 18, staffing. Sufficient numbers of suitably qualified, competent, skilled and experienced staff must be deployed, and staff must receive the training and supervision they need. Numbers are the visible half of this, and competence is the half that gets missed, because training does not equal competence and a completion matrix does not evidence that anyone can actually do the thing. Safe and effective staffing is also where distributed leadership earns its place, through champions who are given real remit rather than a title.
• Regulation 19, fit and proper persons employed. Recruitment must be safe, with the required checks completed and staff of good character employed. This is one of the few areas where an inspector can find a breach in ten minutes without speaking to anyone, so recruitment files that meet Regulation 19 and Schedule 3 are worth checking before someone else does.
• Regulation 20, duty of candour. Services must be open and transparent when something goes wrong, including notifying and apologising to the person affected. The failure here is rarely dishonesty, and is more often a delay while the service works out what happened, by which point the family has already decided how open the service was willing to be.

The champions point under Regulation 18 is worth expanding, because it addresses a failure mode that framework changes tend to reveal rather than cause. In a lot of services, understanding of the regulations sits almost entirely with the registered manager, and everyone else works to instructions without knowing which requirement those instructions exist to meet. That holds until the manager is on leave, moves on, or is consumed by a difficult fortnight.

A medicines champion who understands that their role exists to support Regulation 12, or a dignity champion who can connect their work to Regulation 10, becomes a second pair of eyes on practice rather than a name on a noticeboard. Handed out without time, remit or support, champion roles become another artefact that looks like assurance without providing it. Carevia Pro+ includes a Champion Strengths Profile for this reason, because matching a role to a person's actual strengths is what makes it stick, and it produces a record of distributed leadership that an inspector can follow.

There is a practical discipline that follows from all of this. Write your audits, action plans and governance minutes so they reference the regulation they relate to, rather than the assessment heading of the moment. A finding recorded as a Regulation 12 risk stays legible in five years, whereas a finding recorded only against a Quality Statement number becomes an orphan the moment the framework changes.

What genuinely needs to change, and in what order

This is not an argument that nothing changes. Some work is real, and pretending otherwise would leave services exposed when the final frameworks publish. The order matters as much as the list, because doing these in the wrong sequence is how a small indexing job becomes a six-month project.

First, read the rating characteristics rather than the headings. The draft descriptions of what care looks like at each rating level tell you how judgements are expected to be reached, which shapes what evidence is worth holding. The headings only tell you where to file it, so reading them first tends to send people straight into folder-building.

Second, map your evidence index once, working from what you already have. If you organise evidence by Quality Statement you will need a route from your existing material to the new KLOEs, and that is an indexing job rather than a rebuild. Start from your evidence and find its home in the new structure, not from the new structure looking for evidence to fill it, because the second approach produces folders built for an inspector rather than records built for a service.

Third, restructure any self-assessment tool built on the 34 Quality Statements. A self-audit whose headings are the framework genuinely does need rebuilding, and this is one of the few places where the framework really is the tool.

Fourth, check the substance separately from the mapping. Take three or four recent events and follow each one from the original record through to whether practice changed and whether staff on other shifts can describe it. That exercise tells you more about your readiness than any mapping document, and it is the same test an inspector applies.

Fifth, brief the team close to implementation. Staff who have learned to answer questions framed around Quality Statements will hear questions framed differently, and that is a supervision matter rather than a systems one. Language changes are easier to absorb when they are immediately relevant, so briefing people months early usually means doing it twice.

Then leave the rest alone. Your audit cycle, governance calendar, supervision structure, learning processes and risk management were built on the regulations and on what makes a service safe, so they should survive the change intact. If they would not, the problem was there before the framework moved, which is a separate conversation covered in why many audit systems fail.

The indexing work is also the part a membership should absorb on your behalf. Carevia toolkits are written against the regulations and the current assessment methodology and are updated as guidance changes, with those updates included while you are a member. The Inspection Readiness Dashboard will be rebuilt against the sector-specific frameworks once they are final rather than against a draft that may still change, and members will inherit that work rather than repeating it in every service. Recommending patience to members while rebuilding early ourselves would be inconsistent.

The test that survives every framework: RAOF™

If the assessment language keeps moving, leaders need a way of knowing what is happening in the service that does not depend on the language at all. RAOF™ is that habit. It is not an audit and it is not another framework to map evidence against, but four questions that can be asked about any area of practice, in any inspection regime.

None of those four questions mentions a Quality Statement or a KLOE, and that is the point. When the framework changes the mapping changes, but the leadership habit does not, and a manager who knows what is happening on the floor can answer questions posed in any regulatory language because the underlying knowledge already exists.

Where RAOF™ finds drift, the action then needs to close properly rather than simply be written down. That is why Carevia tracks actions through to Tested and Embedded rather than stopping at Complete, an approach set out in closing the loop on actions. An action that is complete has been done once, whereas an action that is embedded has changed how the service works, and that is what holds up when someone follows the chain.

Frequently asked questions

This article discusses governance, regulation and inspection readiness in adult social care. It is not legal advice and it is not clinical guidance. Frameworks under pilot can change before implementation, so always refer to current CQC publications and use professional judgement in your own service.