Consultation outcome

SCCIF review (interim inspections of children’s homes and residential holiday schemes for disabled children): report on the responses to the consultation

Updated 11 March 2022

Introduction

On 2 November 2021, Ofsted launched a consultation setting out proposed changes to the social care common inspection framework (SCCIF). In particular, we consulted on changes to how we carry out interim inspections of children’s homes and how we inspect residential holiday schemes for disabled children (RHSDCs). We were seeking the views from the public as well as those working in the sectors covered by the framework. This followed 4 months of evaluation and informal engagement with stakeholders.

The consultation ran for 12 weeks, closing on 24 January 2022. We proposed 3 changes to the way we carry out interim inspections of children’s homes and 4 changes to the way we inspect residential holiday schemes for disabled children. In total, we received 125 responses to the consultation. This report summarises those responses and sets out how the SCCIF will change from 1 April 2022.

The consultation method

The consultation was promoted on GOV.UK and social media as well as through writing directly to an extensive list of stakeholders.

Stakeholders included:

  • registered children’s homes and holiday scheme providers
  • service users and parents
  • volunteers and staff members
  • organisations, statutory bodies, charities and individuals involved in the work that we carry out

Summary of responses

Responses to this consultation were mostly or wholly supportive of our proposals. Most responses related to interim inspections and came from responsible individuals and registered managers of children’s homes. We also had responses from a range of other providers, including local authorities and voluntary organisations.

We are confident in our revised approach but will review its effectiveness as part of our routine framework evaluation during early implementation.

Who responded

Figure 1: respondents who completed the online survey

Respondent type Number
Local authority Director of Children’s Services 1
Other local authority director or assistant director 1
Practitioner in social care 2
Senior manager in social care 9
Other primary care professional 1
Children’s homes  
Responsible individual for a children’s home 34
Registered manager for a children’s home 44
A volunteer or staff member at a children’s home 7
Residential holiday schemes for disabled children  
Responsible individual for an RHSDC 2
Registered manager for an RHSDC 4
Other  
Prefer not to say 3
Other 12

Findings in full: interim inspections of children’s homes

Following the amendments to the Fees and Frequency of Inspection Regulations, we proposed some changes to our methodology for carrying out interim inspections of children’s homes. In developing the proposals, we considered our learning from carrying out assurance visits during the pandemic, the most recent inspection data and intelligence that we hold.

We believe that this model will enable us to be more responsive and focused on children’s progress and experiences. It will allow us to better check whether children are well cared for and safe, and whether leaders and managers are effective. It will also provide scope for the provider to demonstrate any improvements it had made.

We proposed to:

  • provide a single judgement based on the inspection findings
  • evaluate the effectiveness of any improvements leaders and managers have made since the last inspection
  • replace ‘interim’ with a more meaningful name

Proposal 1: provide a single judgement based on the inspection findings

Interim inspections currently result in a relative judgement that declares a home to have improved, declined or sustained its effectiveness since the last inspection. For someone reading the report to gain a clear understanding of the home’s performance and to put the judgement in context, they would also need to refer to the previous Ofsted report.

We proposed to replace the current relative judgement with a single judgement based on the findings of the inspection. Each report will clearly state whether or not inspectors identified any serious or widespread concerns and provide greater clarity for the reader about the current state of the home.

The judgement will be either:

  • We did not identify any serious and widespread concerns in relation to the care or protection of children at this visit.
  • We identified serious and widespread concerns in relation to the care or protection of children at this visit.

This change will enable us to better respond to concerns about practice and provide better information to commissioners.

What people told us

Figure 2: responses to proposal 1

Answer choices % of responses
Yes 70.48%
No 11.43%
Don’t know 18.10%

Most responses were positive. In total, over 70% agreed that a single judgement based on the home’s current situation would be meaningful, allow effective decision-making and offer improved clarity and transparency for readers of inspection reports (such as providers and local authority commissioners) without them having to refer to the previous report.

Some people also commented that the current judgement scale could cause confusion. For example, a home may have ‘improved effectiveness’ but standards of care could still be compromised, or a service may have declined but not to a level that is concerning.

A small number of respondents said they could not agree or were unsure. These were mainly registered managers and responsible individuals. They expressed concerns that the single judgment may not provide the level of detail required to provide a clear picture of a home’s progress and previous reports that provide context around the original judgement would not be considered.

Our response

By introducing a single judgement on the current findings, rather than a relative judgement, we move away from a focus on progress since the last full inspection to a judgement about the home’s current situation. This will provide a much clearer message to commissioners and providers (as the main readers of our reports) about our findings.

This single judgment will also provide a clear basis for any subsequent enforcement action to ensure that children are well cared for and safe, and that leadership and management are effective.

We acknowledge concerns expressed about providing enough detail in reports so that a clear picture of progress is given. We will give clear guidance to inspectors that they should consider improvements, progress and concerns and appropriately reflect these in the body of the report.

Proposal 2: revise the inspection activity for interim inspections

Currently, interim inspections focus on a range of inspection tasks to reach a relative judgement on the home’s progress since the last inspection. We are now moving to a single judgement based on the current inspection findings (as set out above in proposal 1) that will provide a clearer picture of how well the home is operating at present.

This will enable us to be more responsive and focused. It will also help us to carry out inspections where they are needed to keep children safe, and will therefore make better use of our resources.

We set out our proposals to revise the inspection activity for interim inspections. We proposed to focus inspection activity on 3 areas:

  • whether children are well cared for
  • whether children are safe
  • whether leaders and managers are effective

Inspectors will spend time:

  • talking to children about their experiences of living in the home; and reviewing arrangements for keeping children safe.
  • assessing the effectiveness of leaders and managers by talking to them and their staff
  • reviewing the effectiveness of the monitoring arrangements and the impact of any improvements since the last inspection

What people told us

Figure 3: responses to proposal 2

Answer choices % of responses
Yes 85.71%
No 7.62%
Don’t know 6.67%

We asked whether we were focusing our proposed inspection activity on the right things. Over 85% of respondents agreed that these were the key areas to safeguard and promote the well-being of children. Respondents also commented that the proposed change in the inspection methodology is a welcome one and that the quality standards can be covered in these 3 areas.

Our response

We will implement the new methodology on 1 April 2022. The inspection activities we carry out will provide better assurance that children are well cared for and safe, and that leaders and managers are effective. We will retain key inspection activities that enable us to assess whether progress has been made on requirements and recommendations made at the last inspection and allow scope for inspectors to follow any key lines of enquiry relating to the home.

Proposal 3: replace ‘interim’ with a more meaningful name.

The name ‘interim’ was given when second inspections took place at certain intervals. In September 2021, the regulations were amended. The necessity to carry out a second inspection is now determined by the home’s most recent judgement, rather than its judgement in the previous year.

The purpose of the second inspection of a children’s home will be to provide assurance that the home has not declined since the full inspection and to ensure that children are well cared for and safe, and that leaders and managers are effective.

We therefore recommended the name ‘assurance inspection’ and asked whether this name clearly and accurately reflects the purpose of the inspection.

What people told us

Figure 4: responses to proposal 3

Answer choices % of responses
Yes 77.88%
No 11.54%
Don’t know 10.58%

Almost 80% of respondents agreed the name ‘assurance inspection’ accurately reflects the purpose of the inspection: to provide assurance that children are safe and cared for. Some suggested that it may be confused with assurance visits carried out during the pandemic. However, most said that retaining ‘assurance’ was a positive change. They said the name is easier to understand, more meaningful and makes the inspection sound more child-focused than ‘interim inspection’

Our response

From 1 April 2022, we will rename the inspections ‘assurance inspections’ as this more accurately describes them. We believe this will add clarity and help people understand the purpose of the inspections.

Findings in full: inspection methodology for residential holiday schemes for disabled children

We had an opportunity to review our methodology for inspecting RHSDCs following the pause in inspections due to the pandemic. We wanted to ensure that we remain focused on the arrangements to safeguard and promote the welfare of children, while having a proportionate approach to inspecting a scheme where children are on a short holiday so as to limit the burden the inspection process places on providers.

We proposed to:

  • update the language and emphasis in the SCCIF for RHSDCs
  • use a combination of on- and off-site inspection activities
  • require schemes to provide a formal notification of the proposed date and location they will run from
  • carry out an interview by video call with the manager before the scheme starts

We received 19 responses to our proposals. This reflects the low number of holiday schemes that are in operation. However, we are pleased to confirm that we received responses from all holiday schemes that are currently registered in England.

Proposal 4: update the language and emphasis in the SCCIF for RHSDCs

In places, the language in the SCCIF is less relevant or applies differently to holiday schemes compared with other social care settings like children’s homes.

We proposed to revise the language, increase the emphasis on the child’s experience, and reduce the focus on their progress. By rephrasing parts of the SCCIF and including more references to the needs of disabled children, it more accurately reflects what happens at a holiday scheme. We believe an updated SCCIF will enable us to focus on the experiences of children and be more proportionate when inspecting schemes.

What people told us

Almost everyone who gave their views agreed that it is difficult to assess ‘progress’ and ‘achievements’ during a holiday, especially when the focus of the holiday is for children to have a positive and enjoyable experience. Most also commented that refocusing the SCCIF on the child’s experience is a more appropriate way of assessing the holiday scheme’s effectiveness and would make inspection gradings fairer and more relevant.

Our response

On 11 March, we will publish a revised SCCIF for RHSDCs. We will maintain the spirit of the SCCIF but we will include amendments that recognise these schemes are ‘one-off’ events run by staff and volunteers, rather than enduring services like children’s homes.

We will make more reference to disabled children and increase the emphasis on the child’s experience and reduce the focus on their progress. We will remove references to ‘contact’ supervision and qualifications, and replace them with phrases that are more relevant, for example: ‘Children should be given the opportunity to keep in touch with their parents as frequently as they wish to’ and ‘The experiences that the children have on holiday are exceptional, and their interests and abilities are taken into account’.

The revised SCCIF will also set out what we do if we find concerns at the holiday scheme.

Proposal 5: use a combination of on- and off-site inspection activities

Currently, inspectors spend up to 2 days on site during an inspection of a holiday scheme. This involves organisers spending time with the inspector rather than working with the children. We believe that, by using a combination of on- and off-site activity and remote evidence-gathering, the inspection will be more proportionate and focused.

We proposed that some inspection activities will take place off site, before the scheme starts, where appropriate. This includes activities such as planning and discussions with organisers, professionals, and parents. This will reduce the time needed on site.

Inspectors will spend up to 1 day on site, which places less burden on organisers. Inspectors will use their time on site to:

  • carry out observations and conversations with children and volunteers
  • review the site, including sleeping arrangements
  • review incidents
  • review arrangements for mealtimes and medication

What people told us

Almost all respondents agreed that remote evidence-gathering (where appropriate) could be completed effectively before the scheme starts to operate. Many highlighted that managers had already been providing evidence in advance of inspections before the pandemic.

Those who commented said that currently the inspector spends too much time on site. The majority of respondents agreed that a reduction of time on site would mean that responsible individuals and managers could focus on the effective running of the scheme and the quality of care provided for children.

We asked whether it was appropriate to survey parents. Around 75% of respondents agreed, as long as a range of appropriate channels were used.

Our response

From 1 April 2022, we will introduce the revised methodology, in line with our proposals.

We will work with providers, professionals, parents, carers and children where possible to gather evidence remotely. We will reduce the time on site from 2 days to half a day and carry out a variety of inspection activities off site. This includes surveying parents to ensure that their views are captured. These changes will enable us to carry out a more focused and proportionate inspection of holiday schemes.

We will review the changes in practice to ensure that they continue to be effective. There will always be scope for the inspector to increase their time on site should concerns arise. We will ensure that inspectors have the necessary guidance and resources to carry out these inspections.

Proposal 6: require schemes to provide a formal notification of the proposed date and location they will run from

We proposed that schemes will be required to provide a formal notification of the date and location of the holiday by the end of April each year. This will help us plan and coordinate our inspection activities more effectively and reduce the disruption caused by inspection.

What people told us

Many registered managers and responsible individuals agreed and confirmed that they already do this or think it is achievable. Some providers stated that they may not be able to confirm actual dates and venues if their proposed scheme was to operate later in the year. They asked for some flexibility, for example for October half term or Christmas schemes.

Our response

From 1 April 2022, we will require schemes to provide a formal notification of the proposed date(s) and location(s) they will operate from. This will help with inspection planning. In response to what we were told, we will amend the notification form that providers must complete. The form will ask providers to notify us of their ‘intention to operate’ in April and ask that they confirm around 3 months before the scheme operates or when they have firm plans in place.

Proposal 7: carry out an interview with the manager before the scheme starts

We currently interview the registered manager on site on the first day of inspection. By engaging with managers before the scheme starts (where possible), they can focus on the running of the holiday scheme and the inspector can spend more of their time on site observing how it operates.

We proposed that inspectors will contact the responsible individual or manager approximately 10 days before the first day of the scheme to:

  • agree the most suitable time to visit
  • arrange a manager’s interview by telephone
  • review the arrangements for the scheme, such as recruitment and planning

What people told us

Again, agreement with the proposal was high. Those who commented said it is practical and reasonable to hold a manager’s interview by telephone or video call on an agreed date about 10 days before the scheme starting.

Some responsible individuals and registered managers expressed concerns around what would happen if they were unavailable. However, others stated that less time carrying out on-site inspection activities meant more time for holiday scheme managers to spend supporting their staff and children. They saw this as a positive change.

Our response

Inspectors will contact the responsible individual or registered manager approximately 10 days before the first day of the scheme. Inspectors will work with the provider to arrange a manager’s interview (at an agreed time), review the arrangements for the scheme such as recruitment and planning, policies and risk assessments and agree the most suitable time to visit.

Next steps

We published the revised SCCIF on 11 March 2022 alongside this consultation response, which comes into effect from 1 April 2022

We’re always looking at ways we can improve the way we work. We will continue to review these arrangements to ensure that they enable us to meet our regulatory objectives and responsibilities.

Equality, diversity and inclusion

As part of the consultation, we published a draft equality, diversity and inclusion (EDI) statement.

We have considered carefully all the comments that we received about equality, diversity and inclusion. There were no concerns that the proposed changes would have a disproportionate impact on individuals or groups who share protected characteristics. We have published the final version of the equality, diversity and inclusion statement alongside this consultation outcome.