The time is fast approaching for providers of NHS general practice and primary medical services in England to register with the Care Quality Commission (CQC).
There are three stages and the first, setting up an online CQC account, is scheduled for July 2012. The second stage, applying to register, runs from September to December and the third, applications assessment by the CQC and formal registration, to April 2013.
Applying for registration
Private medical practitioners, including independent GPs and consultants, have long been regulated by the CQC and the previous Healthcare Commission.
Since the commencement of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2010, regulation of healthcare services has been extended from April 2011 to include dentists and independent ambulance services. Now it is your turn.
If you are an NHS GP who provides or intends to provide regulated activities in England, you are legally required to be CQC-registered on 1 April 2013. The provider is the legal entity that provides a healthcare service to patients and this can be a singlehanded GP, a partnership (two or more GPs) or an organisation (limited company or limited liability partnership).
For GP practices there will be at least one application form to submit and, as part of the process, you may also be asked to provide details of professional and medical referees and to agree to an up-to-date Criminal Records Bureau check.
Bear in mind that the CQC has a history of returning a significant number of application forms to new applicants, often because items of information have been missed or a requested supporting document has been omitted. Extra vigilance should mean you can avoid this.
Healthcare regulation should not be considered as a one-off registration process with the statutory regulator.
Submitting the CQC application form plays a small though key part and GP practices must legally comply with both the CQC (Registration) Regulations 2009, and the Health and Social Care Act 2008 (Regulated Activities) Regulations 2010.
Staying compliant with this legislation and the CQC essential standards, regulations and outcomes involves a continuous process that starts with registration and is then ongoing. This makes having a robust system of clinical governance in place to provide tangible evidence of compliance highly advisable.
An ongoing time commitment is required to ensure a GP practice remains compliant and is always ready for an unannounced inspection by a CQC assessor.
Before submitting your application, you will be asked to formally declare that you are compliant with at least 16 out of the 28 essential standards of quality and safety.
Declaring that you are compliant means that you will need to be ready to provide the necessary evidence. If you are not compliant with a particular essential standard, then you need to formulate a written action plan confirming how and when you will achieve compliance.
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The next steps
In the world of healthcare regulation, time will pass relatively quickly from now until 1 April 2013. Rigorous preparation is vital if NHS GP practices wish to experience a smooth process of registration. CQC registration is undoubtedly new territory for the majority of practices. A system of healthcare regulation focused on patient outcomes requires robust evidence of compliance.
With this in mind, aspects to get on top of now should cover: registered provider, nominated individual, registered manager, essential standards, regulated activities and locations (see box, above).
The time commitment in preparing for CQC registration should not be underestimated. The essential standards, regulations and outcomes are new subject areas for many GPs.
The average amount of time required to prepare a new CQC application will vary according to the size of your practice and how busy it is. This may vary from a number of days to several weeks' preparation.
Do not be put off
With careful preparation and planning, there is no reason why your application for registration with the CQC cannot go smoothly.
Extra vigilance concerning the presentation of the application forms and supporting documents will pay off.
- Gerry Kennedy is an independent healthcare consultant and director of Healthcare Regulation Solutions, firstname.lastname@example.org