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CQC registration for GP practices

Completing the CQC registration will be easier if practices are prepared in advance.

Dr Ian Dunn: believes the CQC has yet to develop a clear idea of what evidence it would accept (Photograph: Pete Hill)
Dr Ian Dunn: believes the CQC has yet to develop a clear idea of what evidence it would accept (Photograph: Pete Hill)

Later this year, GP practices in England must register with the Care Quality Commission (CQC) and the prospect has spawned an array of alarming stories, consultancy offers and sleepless nights.

Registration will open in October and the process, designed to assure the public that practices meet safety and quality standards, will focus on compliance with 16 regulations.

The GPC says that practices may have a lot less to be concerned about than some fear, although those who piloted the scheme say a lot of work is involved.

Painless registration
GPC contracts and regulation subcommittee chairman Dr John Canning predicts CQC registration will be relatively painless and has helped develop the GPC's toolkit that aims to guide GPs through the process. Although GPC chairman Dr Laurence Buckman last month warned of 'substantial' workload.

Dr Canning suggests that, while some practices might struggle, the CQC's expectations will be met by what most practices already do.

Dr Canning warns that the CQC's documentation is 'fairly turgid' and the process will not be free in terms of a registration fee or administration time. While the CQC will not require practices to submit evidence of compliance with their application, they will need to produce evidence on demand.

The CQC may also use information such as QOF performance, results from the national GP patient survey and patients' comments on the NHS Choices site. The latest information suggests the CQC could also look at how practices are doing against NICE's new quality standards. NICE is currently in talks about how these standards will sit alongside the CQC's.

CQC registration and GP practices
  • All GP practices in England must be registered by 1 April 2013.
  • The CQC's 16 essential quality and safety standards include requirements on cleanliness and infection control, safeguarding for people who use services and meeting nutritional needs.
  • Registration will open in October and finish at the end of December. Practices will have 28 days to complete the process of registration.
  • Practices only need to register once but will then be monitored on compliance. They will have to pay an (as yet unannounced) annual fee from 1 April 2012.
  • Sanctions for failure to meet the requirements include warning notices, financial penalties, cancelling registration and even prosecution.


'Confusing paperwork'
The CQC has piloted registration in the east Midlands. Nottingham GP Dr Ian Dunn's practice took part in the pilot and believes the CQC had yet to develop a clear idea of what evidence it would accept.

He says the paperwork was 'a little confusing' but predicts the final version should be manageable but will take several hours to complete. 'The main problem will be gathering the evidence that will support your contentions that you meet the various standards set,' Dr Dunn says. 'I recommend people start to consider what evidence they will need and what mechanisms will be needed to gather it, ideally in a way that is minimal in effort.'

Derbyshire LMC secretary Dr John Grenville, says Derbyshire practices that piloted the system reported that requirements on patient participation and infection control were the ones to focus most on.

The Medical Protection Society (MPS) highlights communication, confidentiality, complaints, health and safety, recordkeeping, prescribing and staff training as areas practices could struggle with.

Dr Grenville adds that most practices will be compliant 'but they may need to look at their paperwork to show that they are compliant.' He believes the requirements though not insuperable for most practices are 'yet another burden'.

  • Use the GPC toolkit published last month.
  • Download documents from the CQC website - www.cqc.org.uk/primarymedicalservices
  • The MPS says a lot of the CQC's focus is on patient participation. Having a patient participation group and undertaking a local patient survey, taking action on it and publicising the results are ways in which practices can demonstrate compliance.
  • Ensuring a service user's privacy and dignity are upheld are important elements of CQC outcome 1, regulation 17, so practices may want to consider how they safeguard for confidentiality.
  • The MPS has identified records management in CQC outcome 21, regulation 20, as another common risk area.

GP social enterprise
Fiona Wood from Gairnswood Ltd, a consultancy offering practices help with registration, used to work for the CQC and has advised the CQC on the new system. She is working with a GP social enterprise to help its member practices register and says getting together in groups is a good way of sharing the workload.

CQC compliance 'is not just a matter of filling in a registration form,' she says, and she warns against focusing too much on producing protocols.

The requirements 'will be interpreted more broadly than policies and procedures and it is a way of working which is outcome-based rather than a tick-box approach,' she says.

The CQC introduced registration for dental practices last year and the MPS says dentists faced challenges with the process. MPS director of policy and communication Dr Stephanie Bown says: 'The CQC seemed to have underestimated the number of providers and seemed under-resourced, lacking the sufficient number of people and necessary expertise to deliver a seamless process.'

She hopes the CQC will be better resourced for GP practice registration. 'We would also caution GPs to check the credentials of any company seeing to assist them.'

Dr Canning adds that there are a lot people touting for business and most are probably offering help that is not really necessary.

Meanwhile Dr Dunn has created a 28-page spreadsheet to ease the process for his practice and suggests that practices familiarise themselves with the CQC requirements now.

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