How to Challenge a CQC Draft Report: The Factual Accuracy Check Step by Step

How to Challenge a CQC Draft Report: The Factual Accuracy Check Step by Step

You have 10 working days to correct errors and add missing evidence. Here is exactly what you can challenge, what you cannot, and how to prepare a response that works.

After an assessment, CQC emails you a draft report and gives you 10 working days to submit factual accuracy comments. You can correct errors, challenge evidence that was inaccurate and add information that was missed. You cannot use the process just because you disagree with a rating or score. If the rating is published and you believe CQC did not follow its process, you can request a rating process review within 15 working days.

The draft report is your best chance to influence the final wording. Once the report is published, most challenges are limited to process failures. Many providers lose the opportunity by missing the deadline, arguing about the rating rather than the facts, or sending no evidence.

This guide follows CQC’s own pages on the factual accuracy check, how to submit comments and the rating process review. CQC notes it may adjust the process, so check the current pages before you respond.

What Is the Factual Accuracy Check?

When CQC has finished quality-checking its draft assessment report, it sends it to you to review. You are asked to check the accuracy and completeness of the information CQC used to reach its judgements and ratings. The process lets you tell CQC where information is factually incorrect or where its evidence is incomplete.

CQC says assessment teams base judgements on all the available evidence and use their professional judgement and scoring model. The final report does not have to reference all the evidence, but it should include the best evidence to support the judgements. See also CQC’s assessment framework in 2026.

How Long Do You Have?

From the date of CQC’s email, you have 10 working days to review the report and submit comments. CQC says it will not extend this unless there are exceptional circumstances. If you cannot meet the deadline, you must tell CQC immediately and in writing why. CQC then uses its discretion.

If there are no inaccuracies, you can confirm you have reviewed the report so CQC can publish the final version.

Make sure the email reaches the right people. CQC sends the email to each registered person, for example the nominated individual and the registered manager. Check that your contact details on CQC’s records are correct. Providers are responsible for ensuring the responsible person has checked the draft and that comments have been approved and submitted.

What Can You Correct or Challenge?

CQC identifies three categories:

1. Typographical or numerical errors, such as incorrect job titles or wrong bed numbers.
2. Information that contributed to a judgement but is factually inaccurate. You must provide supporting evidence, and it must relate to the position at the time of the assessment.
3. Additional or omitted information you think CQC should consider, for example further examples of exemplary practice that could support Outstanding rather than Good. Again, it must be relevant to the time of the assessment.

You can also tell CQC about action taken since the assessment. The assessor will consider it and decide whether to amend the report, but CQC says that, unless there are exceptional circumstances, new information will not form part of its decision on final judgements or ratings.

CQC’s own example

An assessor asks for a safety policy and a senior member of staff says there isn’t one. If you send the policy and show it existed at the time, the assessor can include that in the final report and consider it in the judgement. If you only say you have written one since, the report notes it but it does not affect the judgement.

What You Cannot Use the Process For

CQC says the factual accuracy check should not be used to challenge:

• a rating or score solely because you disagree with it;
• how CQC carried out the assessment, which belongs in a complaint about CQC; or
• proposed enforcement activity, which has its own route for representations.

Keep each comment about a fact. “The inspector said no daily fluid chart existed; here is the chart dated 4 September” works. “We believe this home is Good” does not.

Step by Step: How to Respond in 10 Working Days

1. Day 1: Read, share and diarise. Read the whole report, circulate it to the registered manager and nominated individual, and diarise the deadline.
2. Days 1 to 2: Mark every statement as accurate, inaccurate, incomplete or unclear. Check names, numbers, dates, job titles, bed numbers and quotes.
3. Days 2 to 5: Gather evidence that existed at the time of the assessment: dated policies, audits, training records, rotas, care plans, minutes and emails. Keep a note of the date each document was created.
4. Days 4 to 7: Draft comments. For each point, quote the sentence in the report, say what is wrong or missing, state the correct fact and reference the evidence.
5. Days 7 to 8: Review. Ask a second person to check tone and accuracy. Remove opinion and keep to facts.
6. Days 8 to 10: Submit through the online portal against each section, or as CQC directs, and keep a copy and a record of the date and time.

If you need information from CQC before you can comment, CQC says to keep the request short and specific and justify why you need it. Send it to your assessor, or to enquiries@cqc.org.uk quoting your assessment reference (it starts with AP). CQC does not release inspectors’ full notes, but will consider extracts on a specific issue where reasonably necessary. The online system has a character limit for comments, so check CQC’s guidance on how to provide more.

What Happens After You Submit?

CQC considers your points and any evidence, decides whether to amend the draft and sends you its response alongside the final report. Every factual accuracy response is reviewed by another member of CQC staff who is independent of the original assessment. If CQC has evidence supporting a point and you dispute it without evidence, it may ask you to provide some.

The assessor decides whether any change affects a judgement or rating, and explains that in the response. CQC may also change draft ratings or judgements if it decides the evidence was inaccurate or incomplete.

After Publication: The Rating Process Review

If the report is published and you believe CQC did not follow its own process, you can request a rating process review. The key rules:

• The only ground is that CQC failed to follow its process for making rating decisions. You cannot ask for a review because you disagree with the judgement, reasoning, score or rating.
• Submit it within 15 working days of publication of the rating, using the online form, once per assessment.
• It must come from the registered manager or nominated individual and is limited to 500 words.
• CQC aims to complete reviews within 50 working days. Scores and ratings can go down as well as up.
• It is the final CQC process for challenging a rating.

Other routes exist for other problems: a complaint about how an assessment was carried out, representations about proposed enforcement and, for enforcement decisions, an appeal to the tribunal. See appealing to the First-tier Tribunal and responding to a warning notice.

Whatever the Outcome, Start the Improvement Plan

Use the draft report as an early warning. Any finding you cannot challenge on facts should go straight into an action plan with owners and dates. See how to write a CQC improvement plan, the 2026 to 2028 improvement plan guide and what happens at re-inspection. CQC says it also considers new information when deciding on enforcement, so evidence of fast action still matters.

CQCLogic generates a framework-mapped improvement plan from your CQC inspection data, with task tracking, deadlines and evidence upload for each action, so the response to the report is already in motion before the final version is published.