CQC workforce evidence: what an assessment asks you to produce

"Evidence of compliance with schedule 3 and Fit and Proper Person Requirements".

That line sits on CQC's list of the evidence it looks at in care homes and supported living services, under processes for the well-led quality statement "Capable, compassionate and inclusive leaders". Behind one bullet are the eight information requirements of Schedule 3, applied person by person.

Most CQC workforce evidence works the same way. The framework names a topic in a few words, and a provider turns it into named people and dated checks. CQC qualifies those lists: they are "examples of the types of evidence we will look at", and "we do not expect you to have everything we include here".

An assessment asks you to produce what you already hold.

CQC asks for evidence by email and does not want a prepared pack

"We will email you to tell you when an assessment is starting and may ask you for some types of evidence at this point." Requests for evidence come "most likely by email".

Nothing has to be reformatted or written up. "Where we request evidence, we will use information that a provider has available." Apart from the provider information return, "we will not specify a particular format for the information". CQC then rules out the obvious response: "We do not want providers to prepare specific documents".

That makes CQC workforce evidence a retrieval problem: how long it takes to produce a complete, current answer about named people from records that already exist. No response window is published for a routine adult social care request, so the window is whatever the email gives.

Where CQC workforce evidence sits in the framework in force today

A gap in one person's recruitment records moves the score for a whole quality statement, because CQC stopped scoring at evidence category level.

The framework in force has five key questions, safe, effective, caring, responsive to people's needs and well-led, with quality statements under each. Evidence sits in six categories, and processes carries most of the workforce material.

"Safe and effective staffing" opens on safe recruitment covering all staff, including agency staff and volunteers. The processes evidence CQC lists against it is recruitment records, staff vacancy and turnover rate, staff records including appraisal, training, development and competency, and training in communication with people with a learning disability and autistic people.

A change is coming and none of it alters what a staff file has to contain. Schedule 3, Regulation 18 and Regulation 19 sit underneath whichever framework is in force. The framework above them is being replaced. On 24 March 2026 CQC said it is moving to separate frameworks "that are more specific and relevant" to each sector, one of them adult social care. In the drafts, key lines of enquiry return in place of quality statements, and CQC has proposed removing scoring from the methodology. CQC's June update sets pilots running from June to October 2026, with evaluation in November. "Pilot judgements have no legal standing and will not affect regulatory status or rating." No final framework has been published as at 23 August 2026.

Schedule 3 applies person by person, and "satisfactory" is CQC's word

Every person an assessment names needs the same eight items in their file, set by Schedule 3 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. The schedule has nine paragraphs, eight of them information requirements:

1. Proof of identity including a recent photograph.
2. Where required, a criminal record certificate under section 113A of the Police Act 1997, with barring information where applicable.
3. Where required, an enhanced certificate under section 113B, with suitability information relating to children or vulnerable adults.
4. Satisfactory evidence of conduct in previous employment concerned with services relating to health or social care, or to children or vulnerable adults.
5. Where a person previously held a position involving work with children or vulnerable adults, satisfactory verification, so far as reasonably practicable, of why that employment ended.
6. Satisfactory documentary evidence of any relevant qualification, so far as reasonably practicable to obtain.
7. A full employment history, with a satisfactory written explanation of any gaps.
8. Satisfactory information about any physical or mental health condition relevant to capability, after reasonable adjustments, to perform tasks intrinsic to the role.

The two easiest to conflate are items 4 and 5. Item 4 concerns conduct in previous health or social care work, or work with children or vulnerable adults. Item 5 applies only where a previous role involved children or vulnerable adults, and asks why that employment ended. Item 5 carries the "so far as reasonably practicable" qualifier. Item 4 does not.

The ninth paragraph defines terms. "Satisfactory", throughout the schedule, means "satisfactory in the opinion of the Commission". A provider decides whether to accept the explanation for a fourteen-month gap in an employment history; CQC decides whether it was satisfactory. Where an applicant is considered suitable despite information covered by Schedule 3, CQC asks that "the provider's reasons should be recorded for future reference".

Agency, bank, volunteer and contractor records under Regulation 19

Any agency worker who has taken a shift in your service is a person whose Schedule 3 information you have to produce. Being told the checks were done is not evidence that they were.

Regulation 19(3) requires that information to be available for each person employed, and CQC reads "employed" broadly. It "will include any member of staff who currently works in the service as a volunteer or a contractor, as well as agency or bank staff". The guidance fixes the timing too: the information "must be confirmed before they are employed". Where somebody else did the checking, the duty stays put, because "providers must assure themselves that all checks are complete and satisfactory".

Volunteers are the one relaxation. Regulation 19(3A) removes the full employment history requirement for them, except where they are service providers, directors or registered managers. CQC's own page still shows the pre-amendment text, so quote legislation.gov.uk where the wording matters.

Training, supervision and competence evidence after someone starts

A complete recruitment file says nothing about the person six months later. Regulation 18 requires sufficient numbers of suitably qualified, competent, skilled and experienced people to be deployed, and those employed to receive the support, training, professional development, supervision and appraisal their duties need.

CQC's guidance turns that into dated records. Training needs are identified at the start of employment and reviewed at intervals. Staff are supervised until they can demonstrate the competence to work unsupervised. CQC's Regulation 19 guidance expects Care Certificate standards to assess the competence of healthcare assistants and social care support workers. All staff are trained in interacting with people with a learning disability and autistic people at a level appropriate to their role, with the Oliver McGowan Mandatory Training named by CQC as the source.

Governance of workforce records, and the one return with a fixed deadline

Well-led adds a second test to CQC workforce evidence, about how the records themselves are kept. Access control and version history sit on the same footing as file contents, under Regulation 17. The quality statement, "Governance, management and sustainability" on the framework pages and "Governance and assurance" on the care home evidence pages, expects arrangements for the availability, integrity and confidentiality of data, records and data management systems.

One workforce return carries a published deadline. The provider information return is required by law under Regulation 17(3): registered managers receive an email with a link to the form, four weeks are given, and it runs once per calendar year.

Its workforce questions are counts from your own records: people directly employed on regulated activities, including agency, voluntary and zero-hours staff; leavers over 12 months; vacancies; and full-time equivalent posts, meaning total working hours divided by 35. It also asks how many have completed the Care Certificate.

Monday's email at two care homes

An assessment is starting. CQC asks for recruitment and staff records for a named list of people, including agency workers from the past three months.

At the first home, permanent files sit in an HR folder, DBS certificates in a locked cabinet, agency confirmations in the manager's mailbox, and training completions in a spreadsheet updated monthly. Matching the list to the rota takes the deputy manager most of Tuesday, because shifts sit in the rota system and the confirmations do not. The list runs to 71 people. Nine came through agencies, so nine emails go out and by Friday two replies are outstanding. Four employment histories contain gaps discussed at interview and never written down. Three DBS certificates are more than three years old with no record of a decision about rechecking. What goes back is complete for 62 people and partial for nine.

Every item of CQC workforce evidence above exists at both homes. At the second, each check was recorded against the person when it was run, with its date and its source, agency workers on the same terms as permanent staff. The manager reads the report and sends all 71 that afternoon.

Credentially produces the second version by recording each pre-employment check as a dated event against one candidate record. Audit reporting and a logged activity trail hold each check beside its date and the source it was verified against, for permanent, bank and agency workers in one place. DBS, NMC and HCPC integrations verify against the register and re-check daily, so the current position on a lapsing check is a field instead of an investigation. Reference requests behind Schedule 3 item 4 are chased by automated reminder.

What an assessment team will ask you for next time

The next request arrives by email, names people instead of topics, and sets its own window. For any named list of staff, that means every Schedule 3 item applying to each person, with its date and whoever obtained it, plus the recorded reasons where somebody was appointed despite something Schedule 3 turned up. Induction, competence sign-off and supervision dates have to be current as at the day the email lands, and that holds equally for every agency and bank worker who has taken a shift. Last is the position today on any check with an expiry date, and which of them lapse in the next 90 days. None of it is new work, so a working day is a fair measure of how long it should take.

If the pilots finish on the schedule CQC published in June, an assessment may come to read those records against key lines of enquiry rather than quality statements. The request itself will look the same. It will be for CQC workforce evidence you already hold, about people CQC names, and the date the email arrives is CQC's to choose.

References

1. Care Quality Commission, Care homes and supported living services: evidence categories, Well-led. https://www.cqc.org.uk/guidance-regulation/providers/assessment/care-homes-and-supported-living-services-evidence-categories/well-led (retrieved 23 August 2026)
2. Care Quality Commission, Care homes and supported living services: evidence categories, Safe. https://www.cqc.org.uk/guidance-regulation/providers/assessment/care-homes-and-supported-living-services-evidence-categories/safe (retrieved 23 August 2026)
3. Care Quality Commission, How we gather evidence. https://www.cqc.org.uk/guidance-regulation/providers/assessment/assessing-quality-and-performance/gather-evidence (retrieved 23 August 2026)
4. Care Quality Commission, Assessment framework. https://www.cqc.org.uk/guidance-regulation/providers/assessment/assessment-framework (retrieved 23 August 2026)
5. Care Quality Commission, Evidence categories. https://www.cqc.org.uk/guidance-regulation/providers/assessment/evidence-categories (retrieved 23 August 2026)
6. Care Quality Commission, Assessment, recording the 6 December 2024 end of evidence category scoring. https://www.cqc.org.uk/guidance-regulation/providers/assessment (retrieved 23 August 2026)
7. Care Quality Commission, Safe and effective staffing. https://www.cqc.org.uk/guidance-regulation/providers/assessment/single-assessment-framework/safe/safe-effective-staffing (retrieved 23 August 2026)
8. Care Quality Commission, Governance, management and sustainability. https://www.cqc.org.uk/guidance-regulation/providers/assessment/single-assessment-framework/well-led/governance-management-sustainability (retrieved 23 August 2026)
9. Care Quality Commission, Our March update, 24 March 2026. https://www.cqc.org.uk/news/our-march-update (retrieved 23 August 2026)
10. Care Quality Commission, Piloting, testing and evaluation of new assessment method, 4 June 2026. https://www.cqc.org.uk/about-us/improving-how-we-work/0626-update (retrieved 23 August 2026)
11. Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Schedule 3. https://www.legislation.gov.uk/uksi/2014/2936/schedule/3 (retrieved 23 August 2026)
12. Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, regulation 19, including paragraph (3A) inserted with effect from 15 January 2024 by SI 2023/1404. https://www.legislation.gov.uk/uksi/2014/2936/regulation/19 (retrieved 23 August 2026)
13. Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, regulation 18. https://www.legislation.gov.uk/uksi/2014/2936/regulation/18 (retrieved 23 August 2026)
14. Care Quality Commission, Regulation 19: Fit and proper persons employed. https://www.cqc.org.uk/guidance-regulation/providers/regulations-service-providers-and-managers/health-social-care-act/regulation-19 (retrieved 23 August 2026)
15. Care Quality Commission, Regulation 18: Staffing. https://www.cqc.org.uk/guidance-regulation/providers/regulations-service-providers-and-managers/health-social-care-act/regulation-18 (retrieved 23 August 2026)
16. Care Quality Commission, Provider information return: information for adult social care services. https://www.cqc.org.uk/adult-social-care-provider-information-return (retrieved 23 August 2026)
17. Care Quality Commission, PIR guidance: Staff or workers and carers. https://www.cqc.org.uk/guidance-providers/adult-social-care/pir-guidance-staff-or-workers-carers (retrieved 23 August 2026)