Transcript Who should register as an

A quick guide to
CQC registration
May 2012
Key concepts
This quick overview of key concepts will help you
decide what registration means for you:
 What is your provider type?
 How many locations do you need to register?
 Which service types do you offer?
 Which regulated activities do you provide?
 Who should be your registered manager(s) and
nominated individual(s)?
 Do you comply with the essential standards?
What is your provider type?
 It’s your provider – or legal entity – that needs to
register, not individual locations, each GP working
in a practice or each contract you hold.
 Every provider must tell CQC their ‘legal entity’ or
‘provider type’:
• Partnership
• Individual
• Other organisation (e.g. company, charity or LLP)
 Find out which entity you should register as on
the following slides…
What is your provider type?
– Partnership
For example…
 Four GPs have formed a partnership agreement
and share liability for three surgeries and multiple
contracts. They include details for each surgery on
a single application and register as a partnership.
What is your provider type?
– Partnership
About partnerships:
•
It is the partnership that must register, not each
individual partner.
•
All partners have made an agreement to accept
joint and several liabilities.
•
Each partner is responsible for meeting the
essential standards and accepts joint and several
liabilities.
•
Limited liability partnerships (LLP) should not
register as a partnership but as an other
organisation.
What is your provider type?
– Individual
For example…
 Three GPs are based in the same clinic at the
same address. They share expenses but don’t
share liability so they are separate legal entities.
They each register as an individual.
What is your provider type?
– Individual
Who should register as an individual?
 Sole-traders or single-handed GPs should register
as an individual.
 Individuals register in their own name and are
directly responsible for meeting the essential
standards.
What is your provider type?
– Other organisation
For example…
 A social enterprise has a number of GP practices in
a locality. It registers as an other organisation and
includes details of all its locations, activities and
contracts in one application
What is your provider type?
– Other organisation
Who should register as an ‘Other organisation’?
 A limited company that provides a range of primary
care services across a county, including a GP
practice, a walk-in centre and a GP-led health
centre.
 A social enterprise that provides a number of GP
practices within a locality.
 A limited liability partnership (LLP).
What is your provider type?
– Different models
• There are many other models of service delivery that
may affect how you should register, including:
• Joint ventures
• Franchises
• Hosting arrangements
• Renting arrangements.
• More guidance and information about these
arrangements are available on our website:
http://www.cqc.org.uk/node/445774#legal.
Which regulated activities do
you provide?
 You can think of regulated activities as the
services you provide.
 The 15 regulated activities are related to care and
treatment that require registration with CQC and
are set out in the legislation.
 Some have very specific definitions so you should
check the guidance carefully before you decide
which activities to register:
http://www.cqc.org.uk/node/445774#regact
Which regulated activities do
you provide?
For example…
 You may assume you should register the activity
‘Family planning services’ if you provide the
‘contraceptive services additional service’.
However, this service excludes intrauterine
contraceptive devices and the regulated activity is
specific to intrauterine devices. So in this case you
wouldn’t need to register ‘Family planning services’.
Which regulated activities do
you provide?
The following regulated activities are most relevant to
general practice:
All GPs should register for:
 Treatment of disease, disorder and injury.
Most GPs should register for:

Diagnostic and screening procedures

Surgical procedures

Maternity and midwifery services.
Many GPs should register for:

Family planning services.
How many locations do you
need to register?
 In the registration process the term location is
used differently from common usage:
• Locations are the places where you provide or
manage regulated activities.
• We count any place where people may be treated
as a location if the regulated activities provided
there are managed independently, for example if
there is a separate patient list.
How many locations do you
need to register?
 When you register you need to specify which
regulated activities you carry on at each of your
locations.
 If you have more than one location, you only need
to submit one registration application form, which
should include details about all your locations.
 You are responsible for ensuring your compliance
across all regulated activities provided both in your
main surgery and in any branch surgeries.
Check our examples of locations to register…
How many locations do you
need to register?
For example…
 A practice and branch surgery that share the
same patient list are classed as one location - even
though they are based in separate premises. You
only need to register the main location (i.e. the
location from where the service is managed, staff
are recruited, main records held, etc.). If the branch
surgery has a separate patient list, you should
register it as a location in its own right.
How many locations do you
need to register?
More examples:
 If you visit patients elsewhere – be it at home, in
prison or in a care home – you don’t need to register
these addresses as locations. You can cover these
activities and your compliance with the essential
standards when you register the main practice where
you manage the services.
How many locations do you
need to register?
More examples:
 A GP-led health centre will generally be classed
as a location as it will manage its own patient list.
 As a rule a walk-in centre is a separate a location
as it does not share a patient list with a main
surgery.
Which locations do you need to register?
Which service types
do you offer?
 In your application you have to tell us which service
types you provide at each of your locations.
 Of the 28 service types, the following are most relevant
to general practice:
• Doctors’ treatment services
• Doctors’ consultation services
 Most other service types – e.g. ‘Diagnostic or screening
services’ – are only relevant if this is your sole or main
purpose. Otherwise you don’t need to register for it.
Who should be your
registered manager(s)?
 Registered manager(s) have day-to-day responsibility
for certain regulated activities in one or more locations.
 They share responsibility with the provider for ensuring
that the essential standards are met.
 A provider will need to have registered managers for
its regulated activities if it is:
• A partnership
• An other organisation
• An individual who is not in day-today charge of carrying on the
regulated activities or is not fit to do so.
Who should be your
registered manager(s)?
 Your registered manager(s) is not necessarily the
practice manager.
For example…
A GP partnership with one surgery run by three GP
partners and a practice manager discuss who should be
registered manager…
Who should be your registered
manager(s)?
The practice manager felt uncomfortable with the level of
responsibility and accountability of the role, and after
reading the guidance on www.cqc.org.uk/register, they
decided one of the partners was more suitable.
He was in a good position to both influence the quality of
the service provided by the practice and enable compliance
with the essential standards of quality and safety. He also
had experience in quality assurance at the practice.
Have you chosen your registered managers?
Who should be your nominated
individual(s)?
 You'll only need a nominated individual if you register
as an other organisation; partnerships or individuals
do not need one.
 This person will act as the main point of contact with
CQC.
 It should be someone who has responsibility for
supervising the management of one or more regulated
activities.
 It can be the registered managers’ supervisor but your
registered manager(s) can also be a nominated
individual.
Who should be your
nominated individual(s)?
For example…
A limited company that runs three GP surgeries and two
walk-in centres needs to assign both one or more
registered managers and a nominated individual.
They decide that their Clinical Director should take both
these roles for all locations. This is because he's already
responsible for monitoring the quality of the services and
ensuring their compliance with existing legislation and best
practice guidance.
Compliance with the
essential standards
 CQC monitor compliance against the 16 essential
standards.
 Compliance with the standards is measured in
terms of outcomes for patients.
 When you register with us you must declare
whether you’re compliant with the essentials
standards in each of your locations.
 You can still register if you’re not compliant
with a standard, as long as you manage risks to
patients and staff. You’ll also need to submit an
action plan of how you’re going to change this.
Do you comply with the
essential standards?
For example..
Three GPs in a partnership that runs a main surgery
and a walk-in centre discuss in a practice meeting
whether they meet the standards.
They check their existing evidence for quality
assurance and find that their main surgery is compliant
with all the standards. Their walk-in centre is compliant
with all but 'Safety and suitability of premises‘ because
their landlord has not allowed them to build a
wheelchair ramp.
Do you comply with the
essential standards?
(Example continued)
The partners have already arranged that patients with
mobility issues are visited in their homes. They check
that both existing and new patients are satisfied with
this service.
They consult the guidance on www.cqc.org.uk/register.
They find that, as they have done everything within
their control to comply with the standard and are
already managing the risks and inconveniences to
patients and staff, they can declare that they’re
compliant with this essential standard.
Further guidance
To find out more about these concepts and to see further
examples:
 Visit the GP area of the CQC website:
www.cqc.org.uk/register
 Read The essential standards: Guidance about
compliance:
http://www.cqc.org.uk/sites/default/files/media/documen
ts/gac_-_dec_2011_update.pdf
 Sign up to the monthly e-bulletin on our website:
www.cqc.org.uk/register.