NAAPS campaign on behalf of very small regulated providers
Alex Fox, the CEO of NAAPS, has sent the following letter to Cynthia Bowers, the CEO of the Care Quality Commission, on behalf of very small regulated providers. He writes:
The latest CQC data on care homes shows a continuing trend towards more people being accommodated in fewer, larger institutions. This is at a time when government and the sector have agreed that tailored, personalised care is best, which is often most deliverable within a small, personal setting. We know that CQC value and support small-scale and personalised support, so, in response to your current consultation, I am writing to you to ask if the impact of the planned rises in fees for very small care homes and small community care services on plurality in the provider market has been taken fully into account?
The regulatory burden upon small services has always been disproportionate, with many having to conform to standards set with much larger facilities and staff teams in mind. The new annual fee structure appears to encourage the trend towards larger care homes, who will enjoy a significant reduction in registration fees, whilst homes with one, two or three beds will see fees more than triple. This situation also applies to small domiciliary and regulated community care services, who will see their fees rise from £621 (for services with fewer than two full time equivalent staff) to £1000 (for any service carried out in only one registered location).
We encourage many proprietors of very small care homes, where the care home is fully integrated into family life, to consider whether Shared Lives registration would better suit their needs and values. However, we recognise that for some care home owners this would not be practical or appropriate, because, for instance, they employ staff, which Shared Lives carers do not. These homes can often nevertheless offer a very personalised and homely service and some are members of NAAPS within our Small Community Services category. We also support the development of very small community support services, some of which have featured as examples of good practice within recent DH policy documents supporting the Vision for social care. They are often operating in very challenging financial circumstances, with registration fees already a significant cost, considering their very small margins.
Your impact assessment suggests the changes will have no impact upon competition or upon overlooked/ minority groups and communities. We feel that this assessment has overlooked the competition between small and large providers and the fact that small providers are often designed around the needs of groups or communities whose needs are not otherwise met by large providers.
We will make a formal response to the consultation, but in the meantime, would urge you to reconsider these changes and look forward to your response.
Brilliant letter. Thank you Alex!

