Two independent reviews last year heavily criticised the CQC’s Single Assessment Framework (SAF), saying it was unfit for purpose. The result? The CQC is now rebuilding its approach to assessing health and care services from the ground up.
For dental practices, this is significant. What replaces the SAF will shape every inspection, every published report, and every regulatory judgement made against services for the foreseeable future. Yet many practices may not have heard about it, let alone engaged with it.
At Agilio, we’ve spent the last few weeks reviewing the draft frameworks in detail and have submitted a formal response to the CQC consultation. Here’s what you need to know.
What’s changing and why
The CQC has replaced the single, one-size-fits-all assessment framework with four sector-specific frameworks covering adult social care, mental health, hospitals, and, most relevant to dental, primary care and community services.
The big structural change is the replacement of “quality statements” with the historic Key Lines of Enquiry (KLOEs) being reintroduced and remapped. These are intended to be clearer, more structured questions that describe what inspectors will look for under each of the five key questions you’ll already recognise: Safe, Effective, Caring, Responsive, and Well-Led. Alongside the KLOEs, the CQC has redefined its “rating characteristics” – descriptions of what Outstanding, Good, Requires Improvement, and Inadequate care looks like under each line of enquiry.
In principle, this is a positive direction. The SAF was widely criticised for being opaque, inconsistent, and poorly tailored to individual service types. The move towards sector-specific frameworks, with clearer criteria for judgment, is something the dental sector should welcome.
But the devil, as always, is in the details.
The questions dental practices should be asking
“Which parts of this framework actually apply to us?”
The Primary Care and Community Services framework covers GP practices, pharmacies, dental practices, optometry practices, community nursing, and more, all under one roof. In my opinion, that breadth is a problem because some of the supporting topics under the KLOEs are simply not relevant to dental practice. “End of life and palliative care planning” is a notable example. It belongs in a GP or community nursing context, not a dental surgery.
This isn’t a new frustration. Under the SAF, it was never made clear which quality statements applied specifically to dental practices, and the online inspection reports gave the impression that all 34 had been assessed, when in reality only 7 were used. That gap between what appeared to be assessed and what actually was created real confusion for our customers trying to understand what was expected of them.
We’ve asked the CQC directly: will the supporting guidance that accompanies the final framework make explicit which KLOEs and topic areas apply to each service type? And will all 26 KLOEs be assessed for dental from day one, or will they be phased in – and if so, when, and to what timetable?
“How will we actually be judged under the new framework?”
This one is more fundamental, and it’s a gap we feel the CQC needs to address before the framework is finalised.
Dental practices are non-rated services. That means you won’t receive an Outstanding, Good, Requires Improvement, or Inadequate rating. Instead, inspectors will judge your service as “Regulations met” or “Not all regulations met.” That’s been the position for some time and hasn’t changed.
Here’s the problem: the new framework is built around rating characteristics. They are described as the mechanism by which inspectors make quality judgements under each KLOE. But if those ratings don’t apply to dental practices, what replaces them? The draft framework is silent on this. Will inspectors still use the rating characteristics as an informal benchmark? Will there be a separate judgment methodology for non-rated services? Right now, their position on this is unclear.
This feels like a genuine structural gap, and it’s one of the clearest examples of why a framework designed to span such a wide range of service types needs much more explicit sector-specific guidance before it goes live.
“Are we going to be assessed against suitable KLOEs?”
The draft framework contains 26 KLOEs, a reduction from the previous 34 quality statements; however, some of the KLOEs seem repetitive, for example, “Timely and equitable access” and “Equity in experience”, appear to cover very similar ground. Both relate to ensuring patients can access your services fairly. Both are, in essence, about the same legal obligation: making reasonable adjustments under the Equality Act 2010.
Having two distinct KLOEs for what is fundamentally the same compliance requirement risks duplication, repetition in inspection reports, and confusion about where to address particular equality-related observations. We’ve suggested the CQC consider combining them.
“Why is the CQC starting to ask about staff safety?”
The proposed “Workforce equity and culture” KLOE includes a new topic: staff safety. We have concerns about this, and they’re grounded in something specific.
The Memorandum of Understanding between the CQC and the Health and Safety Executive, signed as recently as March 2024, draws a clear line: the CQC leads on matters involving patients and service users; the HSE leads on matters involving workers, visitors and contractors. That boundary exists for good reason.
Introducing staff safety into a CQC inspection framework risks blurring that line in practice. Inspectors are not HSE inspectors, and dental practices could find themselves facing requests and expectations in this area that should properly sit with the HSE. We’ve asked the CQC to clarify how it intends to define and limit the scope of this topic, and whether the addition has been agreed jointly with the HSE.
What we did about it
As the UK’s leading experts in dental compliance, we’re in a position where individual practices aren’t: we see how regulatory frameworks apply across a wide cross-section of the dental sector, from independent practice to DSOs, and we have the expertise and data insight to engage with consultations like this in depth.
We submitted a formal response to the CQC covering all the above, and more. We raised numerous substantive questions and concerns, including the need for clearer inspection reports, the case for reintroducing structured action plans that specify exactly which regulation has been breached when shortfalls are found (rather than the current “not all regulations met” approach, which tells practices very little), and the inconsistency between the new draft framework and the CQC’s own existing guidance pages, which still reference the old quality statement terminology.
What should dental practices do right now?
- Be aware that this is happening
The consultation closed on 12 June. That doesn’t mean the new framework lands immediately; there will be piloting and testing before it goes live, planned to commence between June and October 2026, and the feedback submitted now will directly shape what inspectors are looking for when they walk through your door.
- Read the draft framework
It’s available on the CQC’s website and can be accessed here. Even a high-level read will help you understand what direction of travel to expect, and flag anything that seems unclear or unworkable for your practice.
- Watch this space
Once the feedback responses have been reviewed by the CQC, we’ll report back on what they heard and what the next steps are. We’ll keep you informed as the picture develops.
Summary
Regulatory change of this scale doesn’t happen often. When it does, the practices that are best prepared and the sector voices that engage early are the ones that shape the outcome. We’re committed to being one of those voices, and to making sure the dental sector isn’t left trying to interpret a framework designed with someone else in mind.
Our customers can be reassured that we will make the necessary changes to our systems in preparation for the new framework and hold webinars to support members during these planned changes.
If you have questions about the draft framework or what it might mean for your practice, sign up for the free webinar, 1pm on 30th June.
