CQC Regulation 15: What Your Care Home Building Needs to Pass Inspection

When a CQC inspection report mentions your physical environment, you are likely to find that Regulation 15 was referenced; it is one of the most frequently cited regulations in CQC inspections of care homes and possibly one of the least understood.
This guide will explain the precise demands of Regulation 15, what CQC Inspectors will be looking for during their tour of your building, and how the types of construction and refurbishment work you undertake will influence your CQC Inspection Rating.
What Does CQC Regulation 15 Require?
CQC Regulation 15 (Health and Social Care Act 2008 (Regulated Activities) Regulations 2014), relates to the standards that apply to premises and equipment in all care registered services. The main aims of Regulation 15 are:
• That the premises from which care is provided should be kept clean, suitably designed for the purposes for which they are used and properly maintained;
• That premises should be, if necessary, sited in an appropriate location;
• The equipment used to provide care should be kept clean, should be suitable for its use, should be properly maintained, should be securely stored and should be used correctly.

As of November 2023, the CQC introduced an assessment of Regulation 15 compliance through its new Single Assessment Framework, particularly under the Quality Statement on Safe Environments. As such, Inspectors are now assessing your building as part of a larger evaluation of whether your building enables safe, respectful care to be delivered – rather than simply providing a clean and well-maintained environment.

The assessment of Regulation 15 is conducted via the "Safe" key question. However, failure relating to the environment can also negatively impact upon the "Responsive" (whether the environment meets individual resident need) and "Well-led" (whether you have processes in place to assess and manage risk to the environment).

Regulation 15 does not specify minimum room sizes or material requirements. What it does require is that the premises are suited to delivering the type of care being delivered. Therefore, Inspectors' decision on compliance with Regulation 15 is based on professional judgment; context counts. An example would be a smaller, older building that is well-kept, clean and adapted could comply with Regulation 15, whereas a newer building with unsuitable flooring and/or inaccessible bathroom facilities could not.

What CQC Inspectors Actually Look For?

Assessing what inspectors say about how you operate your facility, rather than simply looking at the regulation, is more helpful.
Surfaces and Infection Control
Inspectors will determine if the surfaces in your care home meet the cleaning standards necessary for a health-care environment. The ideal surface would be smooth, seamless; however, most often inspectors will find surfaces with joints, cracks, raised edges or textured finishes that harbour contaminants.
Some common examples include:
Carpeted areas that are adjacent to the main dining area or located in an area with high volume of medical traffic,
Grouted tile floors in bathroom areas (bacteria grow within the grout lines),
Wall finishes that are damaged, cracked, or otherwise porous,
Skirtboards with holes or gaps that provide hiding places for dust/dirt,
Coved Skirts (the "seal" created by coving) is considered the benchmark for infection prevention in long-term care facilities.

Bathrooms/Wet Rooms
In addition to potential deficiencies in cleanliness/sterility, inspectors evaluate whether the bathrooms/wet rooms are accessible for the residents that utilise them; whether they can be properly sanitised/cleaned; and whether they are conducive to delivering dignity-based personal hygiene services.
Areas inspected include:
Whether level-access wet rooms exist for those who cannot enter a tub/shower due to disability;
Whether there is enough room to turn a wheelchair in the bathroom area.
Whether handrails are placed correctly and provide adequate color contrast against the surrounding walls;
Whether thermostatically controlled water temperature valves are installed to preclude scalding injuries;
Whether the flooring provides slip resistance when wet or a textured effect.

Bedroom Sizes/Layout
Inspection teams determine whether bedrooms are large enough for the type of care being delivered. Those needing a profiling bed, a ceiling hoist system, a wheelchair, and ample space for two caregivers to assist require far more space than the regulatory guidelines suggest. When bedrooms do not allow safe delivery of care, these will be reported as Regulation 15 findings.
Currently, the minimum size for individual-occupancy care home bedrooms is generally accepted as approximately 14 sqm. However, older homes with less spacious rooms may still be compliant if the overall design of the care environment is satisfactory. However, inspectors will identify where space constraints compromise the delivery of quality care.
Accessibility/Circulation
All individuals living in the care home must be able to navigate it, including residents who use a wheelchair, walker, or other mobility aid, or who need assistance from staff to move about. Inspection teams evaluate corridor width, door widths (min. 800 mm for corridors; min. 900 mm for bedrooms and bathrooms), elevator availability in multi-story homes, and the presence of no-step entry throughout the building.
Maintenance/Grounds Maintenance
Well-maintained buildings indicate the provider's effective management of regulatory requirements. Inspectors document damaged fixtures, peeling paint, broken equipment/fittings, dirty/stained/worn flooring, malfunctioning lighting/equipment and lack of service history. Additionally, inspection teams review documentation related to ongoing maintenance activities (i.e., evidence of a documented maintenance program that was followed).

Fire Safety Infrastructure
The regulatory framework for fire safety (Article 9 in The Fire Safety Order) has its own regime; however, fire safety is also inspected as part of the Regulation 15 assessment. As such, inspectors will assess compliance with respect to: fire doors made to HTM 60 specification, evidence of testing and maintenance of those fire doors, safe passage for evacuation via clearly defined routes and operational emergency lighting.

Outdoor Spaces
There has been an increasing focus on assessing whether outdoor areas are accessible to and usable by residents, particularly in relation to dementia care home settings. Thus, a garden that residents can view from within their rooms but cannot easily access themselves, nor do so safely and independently, is deemed to be a finding under the 'Responsive' domain - related to whether the physical environment meets the residents' needs.

The Most Common Regulation 15 Failures and What to Do

1. Unsuitable bathroom surfaces. Grouted tile floors replaced with seamless sheet flooring - coved skirting throughout bathrooms and wet rooms installed.
2. Inadequate access to wet rooms. Level access wet rooms installed - at least one wet room per floor - en-suite wet rooms for every bedroom.
3. Lack of grab rails. Installation of grab rails on both sides of the toilet, shower zone, and circulation routes. The contrast of the grab rail with the wall behind must be at least 30 LRV points.
4. Damaged or porous floor surfaces. Healthcare-grade specification, non-slip, seamless flooring installed. High-gloss finishes not recommended for dementia settings.
5. Bedrooms that are too small. Review whether your delivery model can adapt to size limitations; in more serious cases, an extension or rearrangement may be necessary.
6. Poor maintenance records. Formal planned preventative maintenance (PPM) schedule implemented. All work is documented after completion.

Using a Regulation 15 inspection finding to develop a refurbishment program
When using a previous inspection report that identified a Finding under regulation 15 or indicated that the quality of your physical environment was inadequate, the best way to develop your refurbishment program is to base it on the inspector's findings. The inspector's findings represent those items most directly related to your potential inspection score; therefore, address those first.
Typically, regulation 15 refurbishments include:
- upgrade of wet rooms and bathrooms
- replacement of flooring with healthcare-grade specifications
- installation of grab rails
- redecoration utilizing acceptable finishes
- maintenance of fire safety systems

Care Home Builders assesses inspection reports with our operator clients and develops a priority list of refurbishment tasks which address the regulatory findings in order of their potential to improve the client's future rating. We can also accompany the inspector during the re-rating process as the contractor of record to verify completion of works to regulatory standards.

Thinking about a care home project?
We provide construction and refurbishment services for care homes throughout London, the South East, the Midlands and further afield. Contact us to discuss how we can support your project, regardless of whether it is a green field build or an upgrade to an existing facility.