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Registering with the Care Quality Commission (CQC)
On 1st October 2010, an important change takes place in healthcare regulation for independent practitioners as a new Act of Parliament comes into being. Gerry Kennedy, Healthcare Consultant offers some advice for those private doctors with new or existing practices that will need CQC registration.
Medical practitioners providing independent healthcare services have been legally required to apply to the CQC to register their private practice under the criteria of the National Minimum Standards (NMS) and Private and Voluntary Health Care (England) Regulations 2001 of the Care Standards Act 2000. However, this particular Act is now in its final stages of life.
On 1st October 2010, the Care Standards Act 2000 is repealed and replaced by the Health and Social Care Act 2008 (Regulated Activities) Regulations 2010. Healthcare professionals (not solely medical practitioners) who provide regulated activities will be required to register with the CQC in order to legally provide independent healthcare services. The provider is the legal entity that provides the healthcare service to patients. This can be an individual, a partnership or an organisation. Core and service-specific standards were part and parcel of independent healthcare assessment for many years. From 1st October 2010, it is “essential” standards that will be the new yardstick. Adhering to processes used to be the key to measuring and assessing healthcare compliance; now it is all about patient outcomes and what patients can expect from providers. Applying for registration All independent healthcare providers that carry out, or intend to carry out regulated activities, must be registered with the CQC and provide evidence that they are meeting the new 28 essential standards of quality and safety. For the purposes of registration, there are several applications forms to complete, professional, financial and medical references to obtain, personal documents to collate, policies and procedures to develop and risk assessments to carry out. In addition, an up to date enhanced level CRB check is required at the request of the CQC. Many readers may well have experience of having a number of CRB checks being carried out over several years by various employers or organisations. Unfortunately, previous CRB checks are not transferrable for CQC registration purposes and a new enhanced check needs to be applied for at the request of the CQC. A further change in this process, already implemented in March 2010, has now involved the 27 Crown Post Offices in England in part of the CQC’s CRB verification process. Time commitment Be warned, the average amount of time required to prepare a new CQC application for submission is approximately 300 - 400 hours. This may seem a high time commitment. However, professional referees often take time in responding to requests for references and building Landlords may be difficult to get hold of to obtain copies of premises’ documents. When you have several documents to prepare, often from scratch, it is important that all paperwork is fully completed, checked, signed and dated and then checked again! The CQC returns a high number of application forms to new applicants, often because an item of information has been missed or a supporting document not included for submission. Approximately 60 to 70% of submitted applications are returned to applicants for re-submission, often for reasons that are avoidable if extra vigilance is applied. It is also important to remember that the CQC will take approximately 12 weeks to process a new application for registration and if the regulated activity being provided is complex, the processing time may take longer. This needs to be taken into consideration when a doctor is planning to commence a new independent healthcare service as intended commencement dates need to be realistic. Always remember that under the Health and Social Care Act 2008, it is illegal to provide a regulated activity without being registered first with the CQC. Helpful information CQC registration can be a complex process. However, the CQC website has helpful information with good explanations about the different stages of the application process. The website is updated on a regular basis, so it is worthwhile becoming familiar with the on-screen pages and where to find particular information. The CQC can also be contacted for help and advice by telephone on 03000 616161. Do not be put off With careful preparation and planning, there is no reason why your application for registration with CQC cannot go smoothly. Extra vigilance in presentation of application forms and supporting documents will pay off. Further information Gerry Kennedy is a Healthcare Consultant specialising in helping doctors and healthcare organisations prepare for CQC registration and maintain compliance thereafter. For further advice and information on applying to the CQC to register an independent healthcare service; Gerry Kennedy MSc
Healthcare Consultant Tel: 07969 618923 E-mail: gerry@healthcare-regulation.co.uk The Care Quality Commission (CQC) can be contacted at Care Quality Commission National Correspondence
Citygate
Gallowgate
Newcastle upon Tyne
NE1 4PA Tel: 03000 616161
Fax: 03000 616171 www.cqc.org.uk E-mail: enquiries@cqc.org.uk