CQC registration

If you provide health or social care services to citizens in England you legally must be registered with the Care Quality Commission. Schedule 1 of the Health and Social Care Act 2008 (regulated activity) regulations 2014 dictates which health and social care activities in England must be registered with the Care Quality Commision. New providers need to be aware that the CQC registration process can take 10 weeks or more and there can be a lot of communication from the CQC.    With a bit of planning and the right consultation, the processes can be made quicker, easier and less intimidating and in this blog we’ll summarise how organisations can prepare to meet the regulations.    

Key Elements:

  • What are you going to offer? 
  • Ensuring you have the resources to do the activity
  • Make certain you have the right people doing the right thing  to deliver the service
  • Being cognisant with the processes needed manage the activity properly
  • Understanding that incidents will occur
  • Post-registration submission activities
 

What are you going to offer?

The registration process becomes a lot easier when providers have a detailed understanding of the services they will offer users, and what services they won’t. This can be made even easier by having an impartial conversation – what is clear in your mind may not be clear to external scrutiny.    By deciding what services you will offer you will be able to decide which regulated activity or activities to register for. By registering for certain activities you are automatically able to undertake others – it is also worth having one eye on the future when registering. You don’t want to reapply in 12 months because you’ve tweaked your business model since registering.    Knowing what you offer will also help you with the following:
  • Writing your statement of purpose 
  • Patient Pathway (whilst not required as evidence for all services – this can be important for understanding where you will need to integrate with other services and therefore where there is a continuity of care risk, where you may need to access records etc) 
  • All of the below steps… 
 

Ensuring you have the resources to do the activity

There are a number of resources you will need to be able to demonstrate you have, or will be able to put in place, before you can be registered. Firstly you will need to evidence you are financially in a position to undertake the activity safely through a Financial Viability Statement and a Liability insurance supporting form.    Next you will need proof you have a premises fit to provide your service. To do this you will need to provide permission from the owner that you can undertake the activity. Ideally the agreement will have the term (period) of tenancy, renewal process and key responsibilities for property maintenance.    Importantly – not just any premises can be a care setting. Alongside access and egress considerations you will need to have thought about legally required infrastructural requirements such as built in infection prevention control, storage of cleaning equipment, medicines management – to name a few.   

Make certain you have the right people to deliver the service, doing the right thing 

You will also need to have the right person as a Registered Manager – this should be the person responsible for the day to day provision of the activity.    Before registering you will need to know what your team will look like – which makes knowing what you want to deliver even more important. Organisations need to demonstrate that they have identified the staffing levels, including the name of leaders, and capabilities needed to deliver the service. They will need to have a clear recruitment policy, a training policy, a record of training and ideally, a record of scope of practice – this is particularly important where clinicians can have different areas of speciality.    

Being cognisant with the processes needed manage the activity properly

All the regulated activities have a list of policies, procedures and evidential documents that you must submit via the CQC’s portal. Each one of the 14 regulated activities presents certain risks – the CQC understands this and therefore also and requires sector specific evidence that you have mitigated these risks.  From day 1 you will need a governance structure. This is critically important as you will need to be able to adapt your service and practices over the first 12 months – after all – to adapt Moltke’s famous quote “no plan fully survives first contact.” As patients and staff start to use and test systems tweaks will need to be made, having a process to identify the changes needed and implement them effectively is crucial.   

Understanding that issues will occur

Incidents will occur. The likelihood and consequences are the controllables. The right people, doing the right thing, in the right place, with the equipment will minimise the chances of incidents occurring – and all the above help demonstrate you can deliver this. Finally you will need to be able to demonstrate that when incidents do occur, they are reported both internally and externally as required. You will need a low threshold for reporting and need to demonstrate that your organisation has the mechanisms to identify and learn lessons.   

Post Registration Submission Activities 

Following submission you can expect a correspondence conversation to start with a CQC that will last approximately 10 weeks. This will be submission dependent and will be a “check and clarify” exchange. Importantly here – you will need to know what is in all of the documents you have submitted. Template documents and copy and paste policies are brilliant at supplying the minimum but be sure your policies are relevant to your organisation and reflect its status at service launch.    Be prepared for at least one interview and a premises inspection.    Following that, your regulated advisor will either recommend your registration is approved or not to a CQC steering committee for their final review. Once your application is approved, you can undertake the activities applied for – whilst preparing for your first CQC inspection which they aim to undertake in the first 12 months of you operating. 

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