You couldn't make it up.
Just go with me on this...
Whilst you were busy trying to fit-in buying Christmas presents, sorting out the spare room for 'his mother', hanging the mistletoe, washing the dog, doing the day job, downloading the NHS Xmas Song, buying a Santa Jumper and planning what to wear for the office party (oh, and what did you get for the Secret Santa), the granite hearts of the DH have been churning-out stuff.
My guess; as you are up to your armpits in baubles and wrapping paper, they think you wouldn't have noticed.
It's partly about the CQC (yes, them again) and the fact the Treasury have said they are not really 'the NHS' so don't benefit from ring-fence funding and have to charge the full cost of running their leviathan to the people they inspect and license.
However, buried in the document is the admission that the changes the CQC have made to their inspection process, deep-diving and what-not, are not covered under the powers to charge under Sec 85(1)(a) of the H&SCAct. (See para 17 onwards).
Call me old fashioned but doncha-fink, when the CQC embarked up their new approach, the Board might have assured themselves that they had suitable powers?
Call me old fashioned, donch-fink it is the role of the Chief Executive and the Chair to take advice?
Call me old fashioned, doncha-fink the Board, who are supposed to hold the executive to account, might have asked, before approving the new arrangements, for an impact and a risk analysis?
What exactly are the non-executive directors there for?
Call me old fashioned, if this was a Trust doncha-fink the CQC would have accused them of sloppy management, being poorly led and shoved the chief executive and the chair out of the door?
There is more...
The CQC say, registration and inspection, their two primary functions are so entwined it is impossible to disentangle them. Really, give me an afternoon and I'll do it for you. It's too difficult because they want to make it too difficult.
The DH want to roll the two functions into one; thereby avoiding having to continue to pay grant aid to the CQC. They have to save 25% of their cash.
The CQC are moving to a full-cost recovery model. That means a hike in fees, yet to be determined. I'll be surprised if it is less than three times as much as you pay now. The CQC full cost is �249.3m.
The DH estimate; '...the total net present cost over a 10 year period of fee increases to be approximately �780m.' Furthermore, they admit '...it is not possible to estimate what the trajectory of fee increases might look like in the absence of the proposed new fee raising power.'
They are consulting on facts they don't have, on a system they are not sure how will work, over legislation not yet passed... takes talent.
It will be for the CQC (following consultation) to set their own fees... read that again; yes, they can set their own fees! Yer 'avin a larf! We all know what consultation means... ziltch! They'll do what they want!
By any measurement I think we know the CQC is poorly run. There have been innumerable Boardroom scrapes. To give them powers to set their own fees, unchallenged and more or less unregulated is like giving a boozer the keys to the off-licence.
To give them a monopoly in what is, after all, only a quality assurance market, must make real Tories in the government cringe.
Sixteen years of monopoly inspection with no obvious return on investment says to me; dump the whole shebang. However, that might be translated into 'Ministers don't care about quality'.
The answer is to break-up the CQC. Empower them as regulators and maintain the register... only.
Oblige providers to show compliance with predetermined QA requirements and to drive costs down, open the market to competing companies who can measure key performance indicators digitally, against algorithms, benchmarking and real time dashboards without the need for charabancs full of staff and block-booking hotels.
All data available, all the time, in real time. Cheaper, accurate and meaningful.
In the meantime; back to the stuffing.