I have today received the following response from the CQC, after seeking clarification from them of the position between the two. (Thanks to Michael Brazendale for raising the matter with me, in my previous blog).
Dear Dr Scott,
Thank you for your email. I’ve liaised with our policy colleagues and the current position is set out below.
- Psychological therapies are a critical part of mental health services and CQC has a role to ensure that people receive safe, effective, compassionate, high-quality care.
- The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 schedule 1 defines what ‘regulated activities’ are and ‘Treatment of disease, disorder or injury’ (TDDI) is a regulated activity defined in schedule 1(4)
- TDDI requires the activity to be provided by or under the supervision of a health care professional or social worker – whether psychological therapies is a regulated activity will depend on the person providing it or supervising it
- CQC therefore regulates psychological therapies that are provided by or under the direct supervision of a doctor, nurse (‘health care professionals’ defined in the Regulations) or a social worker.
Does CQC regulate IAPT services?
- In the IAPT services model, supervision is most likely led by senior therapists (not medical staff), so this would probably not include a nurse, medical practitioner or social worker therefore, CQC would not be able to regulate psychological therapies in IAPT services as they are usually led and supervised by therapists and not a nurse, medical practitioner or social worker.
What does future regulation of psychological therapies look like?
- We are working with DHSC, trade associations and other key stakeholders to identify and understand how we may inspect and rate psychological therapies going forward and to make sure our legislative powers cover all which needs to be covered, which may include IAPT services.
I hope this response is helpful.
Many thanks
Mat
Matthew Hughes
Senior Parliamentary and Stakeholder Engagement Adviser
07384 525677
For information about CQC, including contact details, information about how we use and protect personal data, and how to request information from us, go to https://www.cqc.org.uk/contact-us
He responded very quickly to my e-mail and in depth, for which I have thanked him. I would be very interested in any comments on this missive which I could take forward.
Regards
Dr Mike Scott
I responded today March 22nd as follows;
Hi Mat
Following on from your email of yesterday I note that the CQC believes that:
‘Psychological therapies are a critical part of mental health services and CQC has a role to ensure that people receive safe, effective, compassionate, high-quality care’.
I gather from your e-mail that the CQC role is restricted to coverage of agencies, in which a Doctor, Nurse or Social Worker heads the Service Providing agency. How many Service Providers of Psychological Therapies has the CQC inspected? Are there publicly available reports on the inspections? What proportion of NHS Talking Therapies Providers fall under the orbit of the CQC?
It appears that the scope of the CQC has been limited by the ’The Health and Social Care Act 2008 (Regulated Activities)’ and there is no mention of psychologists. This may be because NHS Talking Therapies in the shape of IAPT did not come into being until 2008 and the Service has slipped under the radar of the CQC. In my experience it is usually a psychologist who is at the head of a local NHS Talking Therapies Service.
If the CQC is to discharge its’ role, it is difficult to see how this can be done without broadening its terms of reference. In terms of the protection of Service Users there can be no justification for the de facto exemption of the great majority of NHS Talking Therapy sites, from CQC inspection. I appreciate that at present the inspection framework has yet to be decided but this is a separate matter from establishing the legitimacy of CQC inspection across all psychological therapies Service providers.
I would be grateful for your response to these matters.
Dr Mike Scott