“We understand any negative impact of our activities on the environment and we strive to make a positive contribution in reducing it and support people to do the same.”
Well, do you?
The above statement is not a pious hope nor a bland statement of intent. It is what each and every social care provider subject to regulation by the Care Quality Commission will be required to demonstrate soon.
The new Adult Social Care Single Assessment Framework (see https://www.cqc.org.uk/about-us/how-we-will-regulate/single-assessment-framework), being introduced this year, introduces the new ‘Environmental sustainability – sustainable development’ criteria to the inspection regime. This is a massive step forward, putting environmental sustainability at the heart of what it means to provide a social care service in which the public can trust.
The new criterion builds on a range of related aspects of the current inspection regime that touch on the wider sustainability agenda. The current regime (see https://www.cqc.org.uk/guidance-providers/adult-social-care/key-lines-enquiry-adult-social-care-services) already tests aspects such as workforce equity and inclusion (W1.9), community engagement (W3.2), fairness and transparency (W1.2), and ensuring staff are supported, respected and valued (W1.3). Many of these aspects carry through to the new Single Assessment Framework, particularly in the new ‘Shared direction and culture’ element. But, this is the first time that adult social care providers will be explicitly be asked about environmental sustainability as part of the inspection regime.
This is, I am sure, just a first step in sustainability moving to the mainstream of how social care provision is assessed. Increasingly, commissioners are asking providers to demonstrate their sustainability credentials in tender exercise. Much of this to date has, frankly, been rather a tick-box exercise. Providers have been able to get away with bland statements of their commitment to sustainability so that commissioners can trumpet their environmental credentials – without really having much effect or impact. But this is changing. I have seen increasingly demanding asks of providers in commissioning tenders on sustainability requirements and with this element becoming far more important in tender evaluations. And this is only going to increase in importance.
We only have to look to the NHS to see what is likely to be coming to the social care sector on this issue. The new NHS contractual requirements for healthcare providers now place very clear contractual obligations on providers around carbon reporting. As of now, all large NHS contracts require Carbon Reduction Plans for suppliers’ emissions. In 2024, this will apply to all procurements in the NHS. And, in 2027, all suppliers will be required to publicly report targets, emissions and publish a Carbon Reduction Plan
for global emissions aligned to the NHS net zero target, for all their Scope 1, 2 and 3 emissions.
This is undoubtedly good news for the many of us committed to ensuring that the social care sector plays its part in building a more sustainable future for future generations. But (there’s always a but!), I do have concerns about the new inspection framework’s inclusion of sustainability criteria. Those concerns centre on the capability of the sector to tackle these issues and, crucially, CQC inspectors’ understanding of sustainability issues to make an informed assessment on these matters.
As far as I am aware, expertise in environmental sustainability issues has not traditionally been a core competence expected of CQC inspectors? Expertise in the sector itself is growing but is still relatively nascent. So, if all of us are to ensure that the new environmental sustainability inspection focus drives meaningful advances in how we deliver against the pressing carbon reduction challenges we face, there must be a rapid upskilling on these issues. There must also be intelligent, mature and open discussion between the CQC and providers in the sector to add depth, integrity and realism in the inspection framework on this vital agenda. Only in that way will we all be able to use this important change to move away from box ticking to meaningful change to address the climate change challenge.
That all being said, the bottom line is that every provider needs to be looking now at their approach to environmental sustainability. In the words of the CQC guidance:
“Be prepared to demonstrate what you are doing to reduce the impact on your environment and how you are incorporating renewable energy, sustainable transport, and environmentally friendly waste management into your day-to-day working.”
The inescapable conclusion is that social care providers need to get on board the sustainability train quickly as it is very much leaving the station!
First published in Caring Times