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How to... Make sense of CQC registration

The CQC wants to see evidence of the effectiveness of practice policies, say Julie Wilson and Dr Nick Clements

Patients: The Care Quality Commission’s role is to ensure that primary care is maintained (Photograph: SPL)
Patients: The Care Quality Commission’s role is to ensure that primary care is maintained (Photograph: SPL)

Next summer is likely to see the start of the enrolment process for GP practices in England to register with the Care Quality Commission (CQC), while enrolment for out-of-hours providers began in September 2011.

The CQC's role is to ensure that all health and social care providers comply with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2010 and the CQC (Registration) Regulations so that quality of care and patient safety in England are maintained and consistent.

All organisations providing regulated activities, such as treatment of diseases, disorder or injury and diagnostic and screening procedures, will need to register. Most health and adult social care providers, such as nursing homes and dental practices, have already registered. Now it is the turn of primary medical services.

Quality and safety standards
Out-of-hours bodies are currently enrolling and the CQC is reviewing the registration process for them to determine how the process should work for GP practices next year.

Practices will need to declare compliance with each of the CQC's essential standards of quality and safety for their regulated activities. This applies to each location if services are provided at more than one. The CQC will monitor your compliance against your declaration for its initial and ongoing decisions about the practice's registration status.

If unable to declare compliance with some CQC standards, you must complete an action plan detailing what you will do to become compliant or how you are managing the risks associated with non-compliance and the date by which you expect to become compliant.

Out-of-hours services have to register by April 2012 and general practices by April 2013. It will be illegal for any primary care service to carry on regulated activities after this time unless it is registered with the CQC.

Outcomes for patients
There are 28 outcomes regulations, of which 16 relate directly to the quality and safety of care by all types of provider. The other 12 may apply differently to different types of provider.

It is not enough to have policies and procedures in place. You will need to show evidence of the effectiveness and impact on the outcomes for patients of any policies, protocols, training and so on. This could include up-to-date public information, details of services available and accurate record systems and clinical audits.

The CQC outcomes regulations are split into five sections:

  • Involvement and information.
  • Personalised care, treatment and support.
  • Safeguarding and safety.
  • Suitability of staffing.
  • Quality and management.

The sections each have 'outcomes' for practices to meet.

For example, the safeguarding and safety outcomes are: safeguarding service users from abuse; cleanliness and infection control; medicines management; premises safety and suitability, and equipment safety, availability and suitability. See also the compliance examples box, which covers requirements for meeting one (or more than one) outcome from two other sections.

Although enrolment and registration will involve time and resources at a time when you may already be under pressure, it will be a good opportunity to review procedures, update your systems and ensure that all staff are compliant.

You can download the CQC's Guidance about compliance: Essential standards of quality and safety (March 2010) www.cqc.org.uk/primarymedicalservices

The examples (below) are from the Medical Protection Society's September 2011 publication Signposting the CQC - Understanding your new registration, available at www.medicalprotection.org/uk


Involvement and information: consent to care and treatment outcome

The CQC will want to check whether the provider has a consent policy that includes, for example:

  • How to obtain valid consent from a patient with capacity.
  • Use of a consent form and what to include.
  • What to do if a patient lacks capacity to consent.
  • Arrangements for seeking and obtaining consent on behalf of children.
  • Whether the policy is available to all staff.
  • Staff have been trained on how to obtain patient consent and there is a record of this training having taken place.

Quality of management: complaints outcome

The CQC will check that there are suitable arrangements to ensure patients and those acting on their behalf have their comments and complaints listened to and acted on effectively, for example:

  • Is there an effective complaints system?
  • Has the organisation appointed a complaints manager and responsible person?
  • Are patients informed of the complaints procedure via leaflets, website information and posters?
  • Are complaints investigated, resolved if practicable, and the outcome communicated to the complainant?
  • Are there processes in place to implement learning from complaints?
  • Julie Wilson is clinical risk programme manager and Dr Clements is head of medical services at the Medical Protection Society www.medicalprotection.org/uk

These further action points may allow you to earn more credits by increasing the time spent and the impact achieved.

  • Read and reflect on the CQC's Guidance about compliance: Essential standards of quality and safety.
  • Review your procedures and practice; check up on staff compliance and whether your systems need updating.
  • Draw up an action plan to remedy areas of non-compliance and implement it before enrolment for CQC registrations start.

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