DUAL Underwriting Perspectives: Reviewing risks on their own merits

Niall Moore discusses reviewing care home risks on their own merits

Niall Moore 

Care Manager, DUAL Social Care

I’m Niall Moore, the Underwriting Manager within DUAL’s Social Care team. I’ve been with DUAL for over 10 years, working in Commercial and Accident & Health before moving into Social Care in 2018. My role is focused on developing and growing our Social Care book, providing bespoke solutions to businesses in the sector, and acting as a referral point on more complex risks.

The role of the CQC

The Care Quality Commission (CQC) is the independent regulator of health and social care in England. Their role is to make sure services provide safe, effective, compassionate and high-quality care.

When it comes to care homes, they assess performance against five summarised areas: Safe, Effective, Caring, Responsive and Well-Led. They then give an overall rating: Outstanding, Good, Requires Improvement, or Inadequate.

Changes to the CQC Assessment 

In early 2024, the CQC rolled out changes to its approach to assessments. Previously, “on the day” inspections were the central component to gathering evidence, with assessments more snapshot based. The new approach builds up a picture over time from multiple sources. This includes digital submissions, feedback from residents and staff, and input from partner organisations, as well as site visits.

In principle, this is a good thing because it gives a more balanced picture, but in reality, the challenge is that it takes longer to update ratings. That means a home that is genuinely improving may be left with a “Requires Improvement” or “Inadequate” rating for much longer than before.

The impact on care homes

Retaining a poor rating can create a cycle of challenges for a care home. Families may be reluctant to place loved ones in a service rated below “Good,” which affects occupancy and revenue. Staff recruitment and retention becomes more difficult in a sector already struggling with workforce shortages. In more serious cases, the CQC can take enforcement action ranging from warning notices to restrictions on registration, or even closure.

Care homes are expected to put together an action plan showing how they will return to a “Good” rating. In my experience, this gives providers the chance to reflect on where they’ve fallen short, implement improvements, and build a stronger platform for the future.

The insurance picture

For many composite insurers, a rating of “Requires Improvement” or “Inadequate” is enough to decline cover outright.

At DUAL, we don’t believe in that approach. We review every risk on its own individual merits. We know that under the old inspection model, any care home could have a “bad day” that didn’t fairly represent the quality of care they provide day to day. And, under the new framework, the delay in updating ratings means many providers are unfairly stuck with a label that doesn’t reflect the progress they’ve made.

That’s why, as long as a provider can show a clear action plan and evidence of improvement, we will consider offering terms. In fact, we sometimes find that a recent “Requires Improvement” rating tells us more about where a business is today than a “Good” rating from four or five years ago.
This approach means our clients aren’t left without access to critical protections, such as Business Interruption, Casualty and Legal Expenses; the types of cover that can make the difference between a Care Home business surviving or not.

The cover we provide

At DUAL, we offer a complete commercial combined package designed specifically for care homes. This includes Property Damage, Business Interruption, Casualty and Legal Expenses, as well as specialist covers that reflect the realities of running a care business. Some of the most important covers being Malpractice/Professional Indemnity, Defined Abuse cover, Loss of Residents’ Effects, Deterioration of Drugs & Vaccines and Loss of Registration.

These covers are vital for care homes. They make sure that, even if a home is going through a challenging period, they still have the protections in place to look after their service users, staff, and business.

Guidance for brokers

For brokers supporting care home clients, I recommend:

• Work closely with your clients as they build a detailed, realistic action plan.
• Make sure it’s treated as an ongoing process, not just a one-off document.
• Keep gathering evidence of improvements and share this with underwriters.
• Reassure your clients that at DUAL, a poor CQC rating is not an automatic barrier to cover.

Looking ahead

The care sector is only going to face more pressure: an ageing population, increased demand, recruitment challenges, tighter local authority budgets, and higher running costs. That makes it even more important for insurers to take a fair and balanced approach.

At DUAL, my focus is on looking at the individual merits of every risk, rather than relying on a single rating. That way, we can continue to support care homes with the protection they need to keep doing their vital work.

If you’re working with a care home client, please get in touch with our Social Care team. We’ll review the risk on its own merits and work with you to find a solution that keeps your client protected.