Preparing for CQC assessment: a resource for principal occupational therapists

This resource was developed following consultation with Principal Occupational Therapists (POTs) from the national and ADASS regional POT networks and incorporates learning and tips from POTs who have gone through Care Quality Commission (CQC) Assessment. We have majored on supporting POTs and occupational therapists (OTs) in leadership roles to develop their narrative for assessment rather than on replicating content which is readily available on the CQC website or elsewhere and to which we have provided weblinks.

As part of our support offer to POTs, we commissioned the delivery of workshops in each ADASS region from January to March 2025 on preparation for CQC assessment. You can get a copy of these workshop slides, along with ‘train the trainer’ notes which can be used to run further workshops with frontline staff by emailing [email protected]. We have also developed a separate resource for Principal Occupational Therapists (POTs) and lead OTs setting out the links between occupational therapy and the Care Act. LINK

We know from discussion with POTs that their questions are likely to include:

• What will the CQC lines of enquiry be?
• Does the CQC understand that the role and remit of POTs varies between different councils?
• What does occupational therapy look like in a ‘good’ or ‘outstanding’ council?
• Do CQC routinely interview POTs and what does this interview look like?
• What if I don’t know the answer to a question?
• How do we prepare ourselves for assessment and possible interview with CQC?
• How do we showcase our value and evidence the outcomes from our work?

This resource aims to increase Principal Occupational Therapist (POT) confidence in participating in Care Quality Commission (CQC) assessment and in evidencing their contribution to wellbeing, prevention and promoting independence under the Care Act 2014. Alongside this resource, we have a companion piece [LINK] which sets out the Care Act duties which are relevant to occupational therapy. The Royal College of Occupational Therapists (RCOT) have also published comprehensive Care Act 2014 Guidance for Occupational Therapists.

Care Act statutory guidance (1.27-1.31) establishes a requirement on councils to have a principal social worker in post and sets out in some detail what the expectations of the postholder are, centring on leadership and oversight of “excellent social work practice.” There is no corresponding statutory requirement to have a Principal OT in post. As far as we can tell (as of March 2025) about 57 per cent of councils have a Principal OT in post. Care Act statutory guidance (6.84) is however clear that:

Scoping work for these resources suggests that where there is no Principal OT role, arrangements for strategic oversight, leadership and accountability for occupational therapy in councils vary considerably. Where OT is outsourced to the NHS or a private provider, oversight of how the service meets Care Act duties on behalf of the council, and the extent to which a PSW in a council with no POT is by default accountable for the strategic oversight and leadership of OT, needs to be clear to CQC. Following their CQC assessment, some councils without a POT have decided to introduce the role. We recommend that POTs (or lead OTs where there is no POT) are involved in set-up and planning meetings with CQC (alongside the PSWs) prior to their visit, and that as far as possible, the Principal or lead OT in the council is always interviewed by CQC, securing support from the Director to be added to the CQC interview list where necessary.

In 2021, the Royal College of Occupational Therapists (RCOT) published a paper setting out the roles and responsibilities of principal occupational therapists in adult social care services in England. This sets the role of the POT in the context of what it calls “Four Pillars of Practice” namely,

• professional practice
• facilitation of learning
• leadership
• evidence, research and development.

Alongside this, RCOT publish the Professional standards for occupational therapy practice, conduct and ethics, as well as some audit tools and a PowerPoint slide deck.

CQC will want to hear about how councils and their POTs or lead OTs use their professional and ethical standards to provide assurance to local people about the quality of their work. Being able to describe how OT standards underpin practice and guide the work of the occupational therapy workforce will be essential, as will how they uphold the registration requirements of their regulatory body, the Health and Care Professions Council.

The Health and Care Act 2022 (1 April 2023) gave the Care Quality Commission (CQC) new regulatory powers to assess local authorities' delivery of their adult social care duties under Part 1 of the Care Act 2014The aim of assessment is to provide assurance to local people about how well local councils are discharging their duties under the Care Act 2014 using a single assessment framework structured around four themes:

• How local authorities work with people
• How local authorities provide support
• How local authorities ensure safety within the local system
• Leadership

Each of the four themes is underpinned by a set of 9 quality statements using ‘we’ statements; you can find these statements in the methodology section on the CQC website.

In December 2024, the LGA published An analysis of local authority CQC assessment reports: What does 'good' look like? which includes more detailed information about the assessment process, the quality statements, evidence collection, scoring and themes from councils who were rated ‘Good’ by CQC.

You can read CQC’s published council assessment reports. This page also hosts the list of councils whose assessments are underway.

There are six stages in the CQC assessment process: 

• 1. Notice of assessment: CQC will send a notice to the Chief Executive and Director of Adult Social Care that they will be assessing the council, usually 6-8 weeks before their onsite visit.
• 2. Review of publicly available data: CQC will review all council data that is publicly available from the Adult Social Care Outcomes Framework (ASCOF), Safeguarding Adults Collection (SAC return), Personal Social Services Survey of Adult Carers in England (SACE return) and other council surveys and published reports; this could include strategies published on the council’s website.
• 3. Information Return (IR) (please note this is not the self-assessment -see ‘The Information Return and the council’s Self-Assessment’ section below).: CQC will request a range of information before their onsite assessment visit. This includes a list of 38 data and document items, 50 cases of which they will pick 10, track 6, and put 4 on reserve. Some of this information must be received within 1 week of the notice to assess is received, and the rest within 3 weeks.
• 4. Onsite visit: During CQC's onsite visit, which usually lasts three to four days, they will interview a range of people. This includes front-line practitioners without managers present, the PSW, people who draw on services and carers, providers, partners, elected members and the adult social care leadership. Increasingly we are hearing that the POT is being interviewed by CQC but this does vary, and they may be interviewed alongside the PSW.
• 5. Rating: Once CQC has finished their onsite visit, they will consolidate the information from the information return, onsite visit, and publicly available data. They will assess against the 9 quality statements and add these up to give a final overall rating of outstanding, good, requires improvement or inadequate. You can read more about scoring and how ratings are arrived.
• 6. Reporting: CQC will send a draft report to the council which includes an overall rating. If the council disagrees with parts of the report and or the rating, an appeal can be launched. Some councils have successfully had their ‘requires improvement’ rating changed to ‘Good’. Once the council CQC have agreed on the report and ratings, the report will finalised and published.
• If a council gets a ‘requires improvement’ or ‘inadequate’ rating, the regional Care and Health Improvement Adviser will work with the Director of Adult Social services to develop an improvement plan.

CQC will seek evidence in support of each quality statement in their assessment framework and have set out the types of evidence they will use in support of their assessment decisions.

Evidence already held or accessible to CQC

• evidence already collected as part of CQCs regulatory activity, for example, insights from partners, providers, people using regulated care
• data on effectiveness of some processes
• outcomes data: Short and Long Term (SALT) data and Survey of Adult Carers in England (SACE) data
• census data
• GP Survey data
• Carers UK data from their ‘State of Caring’ Reports.

Evidence which will be requested from councils as part of the Information Return

• specific policies and strategies
• surveys and other data collected and held by councils (qualitative and quantitative)
• the council’s own self-assessment against the quality statements and relevant evidence
• ‘long’ list of 50 case for case tracking by CQC
• relevant feedback from peer reviews.

Evidence which will be directly collected by CQC

The CQC will wish to hear directly from people who draw on care and support, and unpaid carers, about their experiences (for example, through case tracking and focus groups), and from focused engagement with partners such as organisations commissioned by the councils to provide services, and conversations with council staff, leaders and elected members.

A team of people undertake on-site assessments. There is likely to be someone co-ordinating the onsite visit, a lead Inspector and other Inspectors. There may be other experts, reviewers or specialists involved, alongside CQC senior managers. Be aware that there may be no-one on the assessment team who is familiar with occupational therapy, and we’ve heard that some Inspectors have quite a narrow view of what OT involves.

CQCs approach to assessment continues to evolve and it’s difficult to be specific about what exactly to expect. The knowledge and experience of those undertaking the assessment will vary considerably, as will the focus of the discussions that Inspectors have with POTs and others. 

There is no guarantee that the Inspection team will include experienced OT professionals and in some councils, we’ve heard that Inspectors had a view of occupational therapy which was limited to the role being about equipment and moving and handling. This means there may be an element of educating CQC about the role occupational therapy plays in promoting wellbeing, prevention and independence. We do know that CQC-and government-are very interested in waiting lists for assessment and services, and how risks associated with waiting are managed and mitigated so you are almost guaranteed a question about this for occupational therapy. Vacancies, recruitment and retention of occupational therapists has also been a theme in recent CQC reports. CQC are also regularly asking questions about support for unpaid carers so preparing something which describes how you prevent, reduce and delay the burden of caring on unpaid carers will be important. You can find more tips about preparing for assessment below.

These are two different things. The Information Return (IR) is the information that each council is asked to send to the CQC prior to their visit. You can find details about what’s required on the CQC website. The IR is structured around the four themes and the evidence required is prescribed by the CQC. By looking at this, you can see which evidence items are most likely to relate to occupational therapy. The amount of evidence required is substantial. There are 38 data and document items to be provided, plus a ‘long list’ of 50 cases need to be provided of which CQC will select 10, track 6, with 4 on reserve. Case tracking involves triangulating the data in each case, including speaking to the person drawing on care and support.

Tips

• Ideally, POTs will be involved in selecting cases to go forward to CQC for case tracking. Where this is not the case, the POT will need to know whether OT provision forms part of any cases which have gone for tracking to CQC so they can prepare to answer any questions about these cases. The focus of case tracking is on the person’s journey and outcomes rather than on case file audit. CQC do not routinely speak to practitioners involved in a case and have said they would only do so if they needed to seek clarity.
  
  One of the key data items in the IR is the council’s own self-assessment of how well it’s doing against each theme and quality statements. This is not mandatory but is an opportunity for councils to showcase their work. Where no self-assessment is provided, CQC may need to spend more time on site gathering additional evidence. Any format for a self-assessment is acceptable, however CQC point to the comprehensive self-assessment workbook developed by the LGA and ADASS to support councils to prepare for CQC assessments. Most councils to date have used this workbook which you can find on the LGA website. The first part provides an introduction and overview of self-assessment and the second part is a workbook providing tools and templates which have been developed to support the self-assessment process. There is also an excel workbook and an evaluation template.
• Try to get involved in putting material together for the IR, and in contributing to the self-assessment, as early as possible. This could include proposing OT evidence as part of the council’s IR and selecting cases for case tracking which showcase good OT practice. If you’ve not been involved in the IR, familiarise yourself with the content prior to a CQC visit and interview, particularly the items which relate most closely to occupational therapy such as IR5 (assessment, care planning and review processes and pathways from first contact with council), IR8 (strategy to prevent, reduce or delay the need for care and support), and IR9 (arrangements for access to aids and equipment to promote independence).
• Don’t assume CQC are familiar with the role occupational therapy plays in promoting prevention, wellbeing and independence. There may be an element of educating CQC about the role occupational therapy plays in promoting wellbeing, prevention and independence. Advice from POT colleagues is to start any interview with some scene setting for CQC.O
• If you are new in the POT role, ask for an OT colleague of the same grade to join the interview and answer questions together.
• If you don’t know the answer to a question, say you’ll follow up afterwards by email.

CQC are iterating their approach to assessment all the time, making it difficult to predict exactly what they will ask about. The knowledge and experience of Inspectors can also be a factor, as can expectations of government who we know are concerned about waiting lists and support for unpaid carers. CQC will also take account of data they’ve collected about your council from both published sources and the IR, and issues they’ve identified through their case tracking.

Inspectors will be interested in exploring the main messages and headlines which have emerged from the IR, the council’s self-assessment, the case tracking, and the evidence, data and insights they’ve collected from a range of sources. Some useful things to remember are:

• people’s experience is a required evidence category for all quality statements when assessing councils, and is weighted as highly as other sources of evidence
• CQC are keen to establish how we reach people least likely to experience equitable access or outcomes from council commissioned care and support
• examining how councils encourage, enable and act on feedback from people who draw on care and support, including those who face communication barriers, and how they work with them as equal partners to improve carer support, services and experience, is another key line of inquiry.

The broad outline of an interview with CQC is likely to be:

• Tell me about your job role and your accountabilities.
• How is the job going?
• Who else do you connect with in your job role?
• How does what you do make a difference in people’s lives? Q How do you support those least likely to access care and support?
• Can you give an example of good practice in how you support people?
• What are your main challenges?
• Tell me about your waiting lists and workloads.
• Tell me about your input to reablement.
• Describe how you interface with hospital OT services, hospitals, learning disability services.
• There may also be some specific queries arising from the IR, your council’s self-assessment, case tracking, and evidence collected from a range of sources.

Tips

• In preparing for an assessment interview, another tip is don’t say what you will be doing in the future, but do say what you’re doing NOW, TODAY and can evidence this.
• Legal literacy is important; we’ve heard CQC want to be assured that the councils can describe how things like adaptations are linked to Care Act eligibility and duties.
• It's helpful to know how OT waiting lists are arrived at in your council; although CQC don’t ask for disaggregated data about waiting lists, they will most likely ask about waiting lists for assessments and reviews, and the provision of equipment
• CQC are very keen to understand how the experience of people and carers who draw on support shapes OT support going forward; some examples of this in practice will be useful, as are examples of how OT has learned & changed as a result of feedback or a complaint. You can find some helpful general lessons from the ‘first wave’ of CQC assessments on the LGA website.
• Be aware that CQC could ask you about any of the four domains of their assessment framework and the related quality statements, not just the ones which seem most relevant to occupational therapy. We’ve included some examples you could use or develop at the end of this resource

• Who else do you connect with in your job role?
• Tell me about ways in which what you do makes a difference in people’s lives?
• Can you give an example of good practice in how you support people?
• What are your practice/professional standards?
• How you do you audit cases for consistency & professional standards?
• How do you get work? Talk me through a customer journey/flow from ‘the front door’; what are your messages at the front door for those seeking OT support?
• What are your messages to the public about OT? What’s your universal information and advice offer for OT support?
• What is your approach to assessment in line with the Care Act? What about links with eg housing?
• How do you feed into case discussions where there’s a multi-disciplinary team in play?
• What are waiting times like here? How long are they? How do you communicate with people on your wait list,and how do you manage any risks associated with the wait list? NB CQC may pick up if frequent use is being made of private OTs to reduce wait list-think about your narrative here if this is the case How many hand-offs can people expect?
• How do you deal with provision of equipment, aids & adaptations? What’s your interface with CHC? And with Housing adaptations?
• CQC are interested in physical accessibility as a general issue, plus co-production (with people)-how can you evidence these and how they’ve made a concrete difference? Are these evidenced in any of your policies & processes?
• How do you access training and professional development?
• How are digital or e-tech solutions used in your service?
• What are your main challenges?
• Tell me about OT workloads and staff capacity to meet demand
• Tell me about your input to reablement
• Describe how you interface with hospital OT services, hospitals, learning disability services mental health teams etc.
• What is the role of OT in prevention and how clearly is OT is viewed as integral to effective prevention?
• What is the role of OT in working with people with mental health needs?
• Tell me about the equality of experience and outcomes in relation to people accessing an OT intervention
• Tell me about parity between the PSW and lead OT when the latter doesn’t have ‘Principal’ in their job title...

CQC were interested in outcomes for those with protected characteristics, how we engage with people to ensure everyone is represented, what we are proud of, how the work of the Group manager and Practice lead works alongside the principal social worker.”

POTs who had been through the CQC assessment process have offered the following tips for evidencing and showcasing value and impact in OT:

• Use local health inequality data to demonstrate that you know your local areas needs and are able to target those seldom heard or seen in services; evidence what actions you take to reach those groups.
• Demonstrate how you are fulfilling the lead strategic role for occupational therapy; even if you are not a POT but you are the most senior OT, you can demonstrate your leadership. For example, what responsibilities do you manage regarding policy and quality assurance?
• Highlight integration and partnership working. How do you work with health colleagues and unpaid carers for example? Share good examples of co-production.
• Don’t forget to discuss the visibility and accessibility of the POT role. You could evidence this, for example, by showing that complex cases are routinely discussed, that you advocate for and represent the voice of OT at wider staff meetings, and show how practice improvements are integrated into wider social care practice.

You can find an analysis of CQC assessment reports and ‘What good looks like’ on the LGA website. Occupational Therapy was scarcely mentioned in the earliest reports from CQC, however this has begun to change, with occupational therapy meriting greater attention in more recent reports, suggesting increased visibility with CQC and their Inspectors.

Camden Council are the first (as of March 2025) to achieve an ‘outstanding’ CQC rating. Joint working and sharing between health and local authority staff including occupational therapy was described as “exemplary.” There was a single, central waiting list for assessments and in occupational therapy there was a triage system in place to mitigate risks appropriately. The council had invested in additional occupational therapy posts based in neighbourhood teams though OTs had their own duty team across the whole council area. Investment in this neighbourhood model and an occupational therapy hub had led to vastly reduced or no waiting times for assessments and a reduction in safeguarding concerns being raised.

Wiltshire Council (rated ‘Good’) had quite extensive commentary on their OT provision, with low waiting lists for assessment, a new POT role, an occupational therapy risk prioritisation tool to support the management of waiting lists, involvement in an ‘optimising care’ project with local care providers and using technological and digital solutions to make a practical difference to people’s lives. The council have a quality assurance framework described as “particularly effective” within occupational therapy and a ‘grow your own’ ethos for staff development and career opportunities including occupational therapy apprenticeship schemes.

CQC reports to date give us an idea of what good looks like:

• Occupational therapy is at the forefront of the councils early intervention prevention approach with a POT in place who has equal voice to that of a PSW
• Strong, stable and visible leadership and robust governance and quality assurance arrangements within the service
• Well trained and supported workforce results in a positive culture and good morale
• Evidence of good arrangements to support co-production
• Early intervention and prevention services are prioritised
• Significant evidence of personalised strength-based practice and processes
• Health and social inequalities proactively addressed, with targeted strategies in place to engage underserved populations and those people from seldom heard groups/communities, with culturally sensitive practices in place
• Services are accessible and assessments and reviews are timely, waiting lists managed effectively and urgent cases prioritised L
• earning is actively embedded from feedback/performance data
• Robust safeguarding systems are in place with timely responses and effective advocacy support.

POTs who’ve been through a CQC assessment offered the following learning and insights about using evidence as part of their narrative to CQC:

• Inspectors are seeking to triangulate information on what is being delivered; they want to see evidence of a prevent – reduce – delay approach.
• The IR asks for a lot of data; be prepared to explain the data to people who are unfamiliar with it. Explain patterns and unexpected results.
• Keep some compelling data in your back pocket to use in interviews and conversations
• Sometimes standard performance data doesn’t reflect real progress; context is key; make sure you can evidence your progress and success in a variety of ways.

CQC may wish to explore how POTs use their professional standards and practice guidance to ensure OT services are provided to a consistently high standard and are informed by best practice. Examples of how RCOT guidelines, standards and ethics, the requirements for HCPC registration, and NICE quality standards such as QS182 ‘People’s experience using adult social care services’ are used to improve people’s experience of adult social care will be useful preparation for an interview with CQC.

A mock interview is a useful exercise that can be done with a trusted colleague in the workplace or with a fellow POT or PSW. You can find some guidance on how to do this as part of the LGA.s toolkit to help PSWs prepare for Care Quality Commission assessment.

Quality Statement 1: Assessing Needs

• Support plans tailored to a person’s abilities and goals which support the maintenance and or improvement of functional independence
• Managing waiting lists and ensuring people wait safe and well
• Risk assessment and prioritisation
• Trusted assessor approach

Quality Statement 2: Supporting People to Live Healthier Lives

• Early intervention and prevention/promoting positive risk taking
• Equipment, minor and major adaptations and use of SMART technology and digital solutions

Quality Statement 3: Equity in Experience and Outcomes

• Understanding local health inequalities
• Working with people with protected characteristics
• Reaching people from seldom heard groups/communities

Quality Statement 4: Care Provision, Integration and Continuity

Seamless integration of services by collaborating with multidisciplinary teams, facilitating transitions of care, and contributing to holistic support plans

Quality Statement 5: Partnerships and Communities

Innovation with partners e.g. Public Health, Voluntary Sector, home care and care home providers, huddles with community partners/MDT working (community and acute NHS settings)

Quality Statement 6: Safe Systems, Pathways and Transitions

Implementation of effective strategies for rehabilitation/enablement, home modifications, and equipment provision; supporting reduction of hospital readmissions and promoting stability in care and support arrangements.

Quality Statement 7: Safeguarding

Robust arrangements in place to raise safeguarding concerns and undertake timely safeguarding enquiries 

Quality Statement 8: Governance, Management and Sustainability

Workforce plans to ensure sufficient capacity of occupational therapists and understanding of role of occupational therapy

Quality Statement 9: Learning, Improvement and Innovation 

POT and PSW have equal voice and work closely together in developing robust quality assurance and governance arrangements

The LGA have a list of insights and resources for effectively communicating your narrative in the adult social care self-assessment

Hertfordshire Council and the LGA have shared a suite of resources to support preparation for CQC assessment including Preparing for and managing the CQC assessment, ‘Getting your workforce ready to tell your best story’  and ‘What does adult social care assurance look and feel like and how can councils prepare?’

Royal College of Occupational Therapy 

• Professional standards for occupational therapy practice, conduct and ethics
• Care Act 2014 Guidance for Occupational Therapists.
• Care Act 2014 Guidance for Occupational Therapists-Prevention
• Care Act 2014 Guidance for occupational therapists - Wellbeing

LGA

• The LGA have developed 2 PSW resources which may also be useful for POTs. A Reflective worksheet to help identifying potential lines of CQC enquiry and one on Structuring your thoughts and responses.
• Top tips for CQC assurance preparation
• Occupational Therapy Employer Standards Health Check 

CQC

• Equity in experiences and outcomes
• Assessing quality and performance 

Health and Care Professions Council 

The standards of proficiency for occupational therapists

National Institute for Health and Care Excellence

How to use quality standards