When CQC raises serious concerns: why the first 90 days matter

When a service receives a concerning CQC inspection report, a Notice of Proposal (NOP) or a Notice of Decision (NOD), the consequences are felt well beyond the provider organisation. For people receiving care, it can raise questions about their safety, dignity, routines and the continuity of relationships they rely upon. Families may lose confidence. Staff can feel exposed, anxious or disheartened. Managers may be trying to protect people while responding to intense scrutiny and significant operational pressures.

Having personally led services out of special measures, I know that recovery is possible. I also know that it is rarely straightforward. It demands honest leadership, difficult decisions and the willingness to look closely at what people are experiencing, rather than relying on what the paperwork says should be happening.

The first 90 days at a glance

My starting point is always the person receiving care. Before asking whether an action plan looks convincing, I want to know whether people are safe today. Are medicines administered appropriately? Are safeguarding concerns recognised and acted upon? Do staff understand individual risks, communication needs and preferences? Are people supported with dignity, choice and meaningful involvement in their daily lives?

My starting point is always the person receiving care.

This means being visible in the service: talking with people and their families, observing care, listening to handovers, looking at records and understanding what happens on night shifts and weekends. It is important to hear the experiences of people who may not communicate verbally or who rely on others to advocate for them. Their experience must not be lost behind management assurances.

Immediate risks need immediate action. At the same time, leaders must understand the exact regulatory position, what CQC has identified and the evidence behind it. A NOP sets out proposed action and an opportunity to make representations; a NOD is a further formal decision stage with rights that may include appeal. Providers should take appropriate specialist advice where needed and should never allow the improvement programme to distract from formal deadlines.

I would also look beyond the findings. A poor care plan may reflect weak supervision, an impractical system or a culture in which staff have stopped questioning practice. Repeated medicines errors may tell us more about staffing, competency and oversight than about an individual mistake. Unless we establish the root causes, the same issues will return under a different heading.

Once immediate safety arrangements are in place, the focus must shift to how care is delivered. Updating policies and completing training can be necessary, but neither proves that staff practice has improved. I have seen services produce large volumes of documentation while the everyday experience of people remained largely unchanged.

This stage calls for practical coaching, clear expectations and consistent management presence. Staff need to understand what good care looks like for each person, why changes are necessary and how to raise concerns without fear. Where poor practice has become normalised, it must be challenged. Equally, leaders need to recognise when staff have been working in systems that made it difficult to do the right thing.

The Registered Manager cannot carry recovery alone. The provider and senior leaders must be accountable for resources, staffing, governance and decisions. If managers are repeatedly identifying the same risks without the support to resolve them, the organisation has not addressed the problem.

Families and advocates should not simply receive reassurance that an action plan exists. They should be invited, appropriately and sensitively, to describe what matters to the person and whether they are noticing changes. Their feedback can reveal issues that do not appear in an audit.

By this stage, I would expect to see a developing pattern of improvement, but I would not assume that completed actions equal improved outcomes. I would revisit the original concerns, observe practice across different shifts, speak with people and staff, and check whether changes are consistent rather than dependent on one strong manager being present.

Governance needs to do more than generate figures. If an audit identifies repeated missed care, poor documentation or medication discrepancies, what happened next? Who took responsibility? Did the intervention work? What did the person receiving care experience differently? Those are the questions that matter.

I would want leaders to identify trends across incidents, complaints, safeguarding, staffing and feedback, and to show how that intelligence informs decisions. Where progress is slow, they need to say so and respond. Credibility is built through openness and evidence, not through presenting an unrealistically perfect picture.

Providers should not become so defensive that they overlook genuine concerns. Nor should they feel obliged to accept a factual inaccuracy without question. There is a place for professional, evidence-based challenge through the appropriate CQC processes. But challenging a regulatory finding and making a service safer are two different tasks, and both need proper attention.

Commissioners, local authority quality teams and relevant professionals may also have a role in oversight and support. Clear communication matters, particularly when people and families are worried about what happens next. Any communication should be accurate, proportionate and centred on the interests of people receiving care.

Some services will make substantial progress in 90 days; others will need longer to embed change. There is no universal timetable for restoring confidence or changing culture. Improvement must continue long after an inspection or enforcement milestone has passed.

For me, bringing a service out of special measures has never been simply about obtaining a better rating. The achievement is seeing people receive safer, more compassionate and more personalised care; seeing staff take pride in their work and feel able to speak up; and seeing leaders recognise problems early and act before people are harmed.