Four CQC sector-specific frameworks: what each sector faces

If you run a group that covers both care homes and a mental health service, the framework your compliance team has been preparing for just became two frameworks. Run a primary care network alongside a small hospital outpatient arm and the number is closer to three. From the end of 2026, the Care Quality Commission will assess providers against four sector-specific drafts rather than the single generic framework that has governed inspection since 2023. The five key questions remain identical. Everything underneath them varies by setting.

The shift was publicly signalled in CQC's initial response to "Better regulation, better care" in late 2025, but the operational implications of the CQC sector-specific framework only landed on 24 March 2026 when the four draft frameworks went out for consultation. The consultation closes on 12 June 2026 at 5pm, with pilots through summer, final publication and provider guidance by the end of summer, and implementation by the end of 2026. Compliance directors who treat the transition as one exercise across a mixed estate will mis-allocate evidence effort.

What the CQC sector-specific framework keeps across all four drafts

The shared skeleton is deliberate. CQC has consistently framed the sector split as one framework expressed in four tailored shapes, not four separate regulators. The CQC sector-specific framework splits assessment into four shapes, but the workforce compliance spine underneath is the same across all of them, as is the scoring model that has been removed.

The five key questions remain: Safe, Effective, Caring, Responsive, Well-led. Every sector draft opens with the same five. Keeping them preserves a decade of board and inspection reporting continuity.

The 34 quality statements are gone, replaced by Key Lines of Enquiry framed as structured investigative questions, each sitting under one of the five key questions. The published adult social care draft confirms 24 KLOEs in total (Safe 6, Effective 6, Caring 3, Responsive 4, Well-led 5). The other three drafts carry equivalent structures tailored to sector. Exact counts for mental health, primary care and hospitals have not been summarised in tier-1 coverage and should be read directly from the draft ODT files before compliance teams commit to internal mapping.

Rating characteristics are being re-introduced at each of the four rating levels: Outstanding, Good, Requires Improvement, Inadequate. Anyone who worked under pre-2023 CQC will recognise the shape. They describe what a given rating looks like at key-question level, giving inspection teams a published reference for professional judgement rather than the numerical scoring the Richards review recommended scrapping.

I statements, reflecting lived experience, are retained across all four drafts as the voice-of-the-person anchor running through each sector's rating characteristics.

Rating judgements are now made at key-question level as a whole, rather than aggregated from evidence-category scores. CQC's consultation response sets out that future ratings will be made "directly at key question level, supported by new rating characteristics" using "professional judgement informed by evidence". Evidence category scoring is out. Assessment sits within a risk-based, sector-appropriate inspection schedule, and providers should read the 2025/26 business plan rather than older Single Assessment Framework commentary for the current direction on frequency.

That is the shared scaffold. The detail beneath each key question is where the sector split bites.

Adult social care: 24 KLOEs, and a Well-led burden that is not evenly distributed

Adult social care is the most specified of the four drafts, with 24 KLOEs across the five key questions, covering ground familiar from previous CQC inspections.

Under Safe, the draft covers risk identification and management, safeguarding response, medicines management, infection prevention and control, premises safety, and incident response. These are not new territory. What is new is that each is addressed as a KLOE rather than a quality statement, which rewards fewer, better evidence artefacts over category-mapped libraries.

Under Effective, the draft ranges across care needs assessment, care planning and delivery, staff knowledge and skills, inter-organisational coordination, outcome monitoring, and end-of-life care. Staff knowledge and skills is the KLOE where Regulation 19 evidence sits most naturally, and where completion-of-training records need to read as demonstrated competence rather than logged attendance.

Under Well-led, the draft covers leadership, governance, staff management, financial sustainability and regulatory engagement. Per Skills for Care's "The state of the adult social care sector and workforce in England 2025", the homecare vacancy rate stood at just over 10% in March 2025, against 4 to 5% in care homes. A provider group operating both domiciliary and residential services will be asked to demonstrate workforce stability under the same Well-led KLOEs against materially different operational realities. The evidence burden is not equal by setting.

Professor Martin Green OBE of Care England described the return to sector-specific frameworks as "the right decision and reflects what providers have been calling for" in Care Management Matters. The sector's general reception has been positive. The internal challenge of evidencing Well-led against a workforce gap that varies by service type remains.

Mental health: an 85-day assessment window, and a dual regulatory remit

Mental health inspection combines CQC's assessment remit with its Mental Health Act monitoring function, and the draft reflects that dual role. Chris Dzikiti is currently Interim Chief Inspector of Mental Health, following Dr Arun Chopra's move to Interim Chief Executive in October 2025.

Two operational facts set mental health apart. The assessment completion window runs to 85 working days for mental health and secondary specialist care under the 2025/26 business plan, against 50 working days for most sectors. That gives compliance teams a wider period to respond to inspector queries with live documentation, and means evidence quality has to hold across a longer arc, with staffing rosters, ward-level incident data and Mental Health Act records all in play for longer.

A second distinguishing feature is the density of the workforce compliance spine. Mental health services typically employ psychiatrists (GMC-registered), mental health nurses (NMC-registered), psychologists and allied professionals (HCPC or equivalent), alongside healthcare assistants under enhanced DBS given the vulnerable adult population. Statutory supervision adds another evidence layer, and Regulation 19 evidence has to span at least three professional regulators and demonstrate ongoing fitness, not just initial onboarding checks.

Exact KLOE counts and named topic areas for the mental health draft have not yet been surfaced in tier-1 coverage. Compliance teams should read the ODT directly before mapping internal evidence libraries.

One tension worth naming: the NHS Confederation has warned that narrowly drawn sector frameworks risk missing cross-cutting issues as care becomes more integrated. Mental health sits at that tension point more than most sectors, with community teams interfacing with primary care and crisis pathways with secondary care. The consultation is where that concern is best expressed, before the frameworks harden.

Primary care and community services: medicines KLOEs, and a second programme running in parallel

Primary care and community services is the draft that covers GP practices, community services and related primary care. The most specific piece of published KLOE language across any of the four drafts sits here, covering medicines and treatments: "Are medicines and treatments delivered safely and in a timely way, in line with people's needs and preferences?" Per Dispensing Doctors' Association coverage, the supporting scope runs across prescribing, IV medicines, storage and disposal, controlled drugs, self-medication, antimicrobial stewardship, STOMP and STAMP, and innovative medicines.

That is a deliberately wide remit under a single KLOE. It signals the direction of travel across the new framework: fewer questions with a wider evidence frame, rewarding providers who can narrate competence across a topic rather than tick against narrow statements.

The published Outstanding rating characteristic for this KLOE reads: "People and those close to them are active partners in decisions, assessments and reviews about their medicines or treatment, where possible." That language is the strongest published indication so far of what "Outstanding" will look like in practice under the new approach.

Primary care has a second operational initiative alongside the draft framework. CQC has launched a new assessment programme for lower-risk GP practices, focused on a narrower set of non-clinical quality statements, where assessments do not routinely involve a GP specialist advisor unless concerns escalate. Compliance leads in primary care need to track both, because it changes the inspection profile for a material portion of general practice independent of the framework timing.

Workforce compliance for this sector centres on GP performers list verification, practice nurse NMC checks, healthcare assistant DBS status and practice-level Regulation 19 evidence. The underlying regulations do not change. What changes is that evidence now has to tell the story at key-question level rather than through a 34-part taxonomy.

Hospitals, secondary and specialist care: scale, revalidation, and the 85-day window

Like mental health, the hospital draft carries the same five-question structure, tailored to the scale and specialism mix that defines secondary and specialist providers. Hospitals fall into the 85 working day assessment completion window under the 2025/26 business plan, which matters given the evidence volumes involved at trust scale.

Workforce compliance at hospital scale is its own discipline. Doctor revalidation cycles sit underneath the Safe and Well-led KLOEs, with connected GMC status as the ongoing evidence rather than a one-time onboarding check. NMC checks across thousands of registered nurses, midwives and allied professionals create a pipeline problem as much as a compliance one. Trust-level Regulation 5 governance for directors sits alongside Regulation 19 for staff, and both survive the framework change intact. Every hire has to pass the six NHS Employment Check Standards: identity, right to work, professional registration, employment history, criminal record and occupational health.

Exact KLOE counts and named topic areas for the hospital draft have not been summarised in tier-1 coverage. Compliance leads at trust and private hospital group level should treat the ODT as the primary reference and use the consultation response process to flag any evidence asks that read as disproportionate to acute or specialist operations.

The NHS Confederation caution about sector-specific framing missing cross-cutting issues applies here too. Integrated care and tertiary pathways blur sector lines, and the hospital draft will need to accommodate that blurring rather than pretend it away.

The workforce compliance spine: what does not change

The framework changes. The underlying regulations do not. Regulation 5 (directors) and Regulation 19 (staff) survive the transition and sit directly underneath the Safe and Well-led KLOEs in every one of the four drafts. Ongoing assessment of director fitness and documented evidence of good character remains the reference point for fit-and-proper-persons evidence.

The six NHS Employment Check Standards, mandated by the Department of Health and Social Care for all NHS appointments including temporary and unpaid, sit in the same position. They remain the default documentation shape for any "Safe" KLOE that asks about recruitment or any "Well-led" KLOE that asks about governance. Whatever a sector's draft framework says above them, the six standards remain the operational baseline.

Workforce numbers matter here. NHS England's NHS Vacancy Statistics for Q2 2025/26 put total NHS vacancies at 100,023 in September 2025, a rate of 6.7%. Nursing vacancies sat at 25,500 (6.0%) and medical vacancies at 7,250 (4.4%). The direction is improving from a year earlier. The compliance implication is not. Providers still recruit into double-digit vacancy gaps in some settings, against a draft framework that demands evidence of workforce fitness at every level.

Where Credentially fits

Credentially covers lifecycle credentialing across healthcare specialties, including GMC, NMC and HCPC verification, real-time compliance monitoring, and configurable onboarding workflows tailored per provider type. The sector split does not demand new tooling categories, but it raises the cost of evidence fragmentation across a mixed estate. A group running adult social care alongside hospital services, or primary care alongside community services, will need evidence that tells a consistent Well-led story against rating characteristics that differ by sector.

Credentially compresses platform-managed onboarding steps from an industry average of 60 days towards as few as 5, with DBS and other third-party checks running in parallel across the same 2 to 6 week external windows that apply to anyone else. Spire Healthcare, The London Clinic and Cleveland Clinic London use the platform across their UK operations. Under the new framework, that speed is less about filling vacancies and more about keeping evidence of ongoing fitness continuously available at inspection time.

Connected reading across the Credentially catalogue:

• CQC inspection preparation checklist for workforce compliance covers how workforce evidence maps to the five key questions in practice.
• What HR teams need before inspection sets out the HR-side readiness work that cuts across all four sector drafts.
• Locum and agency compliance matters more where temporary staffing fills sector-specific gaps.
• NMC registration verification, automated and GMC registration check automation cover the primary source verification work that sits under every sector's Safe and Well-led KLOEs, treated as provider-side operational readiness.

What to do next

The consultation closes on 12 June 2026 at 5pm. For any provider with a view on how their sector's draft reads against their operational reality, that response window is the cheapest form of regulatory influence available this year. Preparing a response also forces compliance teams to read the full draft rather than rely on summaries.

The internal evidence audit starts now regardless of consultation feedback. Inventory the artefacts your team currently maps to the 34 quality statements. Re-map against the five key questions for your sector's draft. Park the artefacts that served only the scoring mechanism. The framework change rewards fewer, better artefacts over larger libraries.

The CQC sector-specific framework rewards providers who prepare for their sector, not the generic template. The practical next step for compliance leads working across more than one sector is the CQC inspection preparation checklist for workforce compliance, which maps workforce evidence to the five key questions in the shape inspection teams will use from end of 2026. For the evidence-build side, digital build records that pass inspection covers the documentation discipline that keeps a mixed estate coherent under more than one draft framework.