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CQC registration: Tasks practices should complete before July 2012

Gerry Kennedy explains the CQC registration issues GP practices need to sort out as soon as possible.

Time and deadlines have possibly never been quite so important for GP practices in England as the clock ticks on towards Care Quality Commission (CQC) registration by 1 April 2013.

The big question, is how prepared are you for the first stage of the CQC registration process, commencing in July 2012? This is when the practice will be asked to open its online ‘account’, and your practice should now be considering the tangible preparation that is required before it can apply to register.

Get a move on

Any practice that might be inclined to leave preparations until the last minute is likely to find that it has underestimated the time this preparation takes.

In July you will be asked to choose one of four deadlines by which to send in your application. The second stage of the process, submitting the registration application, starts in September 2012 and runs until the end of December 2012.

For many practices, the whole process of healthcare regulation will be a new area of work and a new terminology to get used to. Not only that, demonstrating compliance with the CQC’s 28 essential standards will ongoing after 1 April 2013. So there needs to be an ongoing time commitment that should be embedded in the everyday running of the practice.

Key issues to consider now
  • Registered provider.
  • Nominated individual.
  • Registered manager.
  • Regulated activities.
  • Locations.
  • Essential standards.

Registered provider

Who is the provider? The provider is the legal entity responsible for providing regulated activities in the form of healthcare services. Your practice will be one of three types of provider – partnership, individual or organisation - that must register with the CQC.

Partnership typically involves two or more GPs working together in a surgery with agreed joint liability for providing regulated activities. Individual GPs in a partnership will not have to register in their own names: it is the partnership entity itself that needs to register. However, one of the partners should be identified as the key contact between the partnership and the CQC.

The best example of an individual provider is a single-handed GP contractor working on their own (with or without salaried GPs’ help) and solely responsible for providing regulated activities to patients. This GP may be in a single consulting room or their own surgery.

A registered provider that is an organisation is where a group of GPs have set up a limited company or a limited liability partnership (LLP).

Nominated individual

Will you need a nominated individual? Where a GP provider is set up as an organisation, for example as a company or an LLP, you will need to nominate somebody at the practice.

The nominated individual’s role involves supervising the management of the regulated activities provided to patients and this person will be the main point of contact between the practice and the CQC. The role is often taken on by the most senior person in the organisation such as the managing director. (There is no need to have a nominated individual for registration as an individual provider or partnership.) 

Registered manager

Who will be the registered manager? Each GP practice needs to identify a person to assume this role. This person will be in charge of the day-to-day running of the healthcare service.

This may be a GP partner or the practice manager. However, the registered manager will be legally responsible alongside a registered provider for ensuring compliance with the essential standards and regulations.  

Registering joint venture arrangements
  • Two or more providers jointly might provide regulated activities.
  • If all the providers collectively form a single legal entity, then this entity must register.
  • But if all providers retain their own individual accountability for providing joint venture healthcare services (through contractual arrangements) then each provider should describe this arrangement to the CQC through their own practice registration. 
  • One example of retained individual accountability is where practices sharing premises have an arrangement for sharing administrative and staff expenses but have separate NHS contracts and do not pool their income.

Regulated activities

How many regulated activities will be provided by your practice? There are 15 regulated activities that require registration with the CQC. The regulated activity that will apply to the majority of practices will be ‘treatment of disease, disorder or injury’.

Other regulated activities that may well apply depending on what healthcare services are provided include ‘surgical procedures’, and ‘diagnostic and screening procedures’.

Locations

How many locations will a practice use to provide regulated activities to patients? If you have more than one surgery premises run by the same GP practice, you will need to include all locations (all addresses) in your application. Fortunately, multiple locations can be included in the same single application for registration.

Essential standards

Are you familiar with the essential standards? There are 28 essential standards set out in the Health and Social Care Act 2008 (Regulated Activities) Regulations 2010. Out of the 28 standards, 16 relate directly to the quality and safety of patient care.

The other 12 essential standards focus on the management of the healthcare service.

GPs should ensure their practices are compliant with all essential standards and are ready to provide the necessary evidence when asked. If there are areas of non-compliance, action plans need to be developed setting out how and when compliance wills be achieved.

Governance arrangements

GP practices should make sure they have robust systems of clinical governance in place appropriate to the healthcare service provided. Ongoing monitoring of the quality of the provided service’s quality is crucial when collating evidence to confirm compliance with the essential standards.

Preparing for CQC registration is just the start of an ongoing healthcare regulatory process that all practices need to be ready for. Good preparation at this stage will pay off.

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