Transcript CQC Registration A practical Guide

John Canning
Secretary Cleveland LMC
July 2012
What is CQC?
 Care Quality Commission
 Replaced 3 previous regulators
 Mental Health Act Commission
 Healthcare Commission
 Commission for Social Care Inspection
 Duty to ensure services meet government set standards
 Funded by registration fees & government grant
 Presently undergoing internal review
CQC and GPs
 Government policy is that all services should be regulated
 Phased approach
 Private providers (including GPs) and social care, private
GPs [registered with previous regulators]
 NHS providers
 Dentists
 OOH providers
 Ambulance providers
 NHS GPs
Registration for GPs
 Two elements
 Setting up an account
 Making the application
 Registration required from 1 April 2013
 Protection for existing providers who register in the
official window even if non-compliant
Accounts
 Do this now
 You will receive
 A letter with your login details
 A code which will allow you to start the application process
 You need to
 Set up an account
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Various people to enable data entry and sign off
 Choose one of four deadlines (between September and
December 2012) to submit your application
 Set up accounts for various people to help you fill in the form and
sign it off
 If you’re expecting to register with CQC and haven’t received
your letter by the end of July, email
[email protected] with your full contact details and
we’ll send it to you.
The Application and Submission Window
 Electronic form
 Do not wait till near the deadline to start
 Can be done in stages
 http://youtu.be/Ct7vgmyjAr0
Terminology
 Individual
 Service types
 Partner/Partnership
 Compliance
 Organisation
 Essential standards
 Registered manager
 Inspections
 Nominated individual
 Regulated activity
 Location
Who registers
 Individual
 Sole practitioner
 Partnership
 The partnership
 You should have an arrangement to share liabilities
 Organisations
 Limited company
 LLP
 Social enterprise etc
 If uncertain ask
Registered Managers
 Required other than for individual registration
 Is in day-to-day control of one or more regulated
activities
 NOT the same as a practice manager
 Usually be one or more partner(s)/director(s)
Nominated Individuals
 Not the same as registered managers
 Required for organisations
 Responsible for supervising the way that the regulated
activity is managed
 Should be an employed director, manager or secretary of
the organisation
Regulated Activities
All practices
 Treatment of disease, disorder or
injury
 Diagnostic and screening
procedures
Most practices
 Surgical procedures
 Maternity and midwifery services
Some practices
 Family planning services
 Termination of pregnancies
Few if any GP practices
 Nursing care
 Services in slimming clinics
 Transport services, triage and medical
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advice provided remotely
Assessment or medical treatment for
people detained under the Mental
Health Act 1983
Management of supply of blood and
blood derived products
Accommodation and nursing or personal
care in the further education sector
Personal care
Accommodation for people who require
nursing or personal care
Accommodation for people who require
treatment for substance misuse
Service Types
All practices
 Doctors consultation services
 Doctors treatment services
 Diagnostic and/or screening
services
Many practices
 Mobile doctors services
Few practices
 Acute services
Unlikely to include
 Prison healthcare services
 Hospice services
 Long-term conditions services
 Dental services
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Hospital for mental health/learning disability
Hospital for substance misuse
Hyperbaric chamber services
Rehabilitation services
Residential substance misuse
treatment/rehabilitation
Community healthcare services
Community LD services
Community MH services
Community substance misuse services
Urgent care services
Care home WITH nursing
Care home WITHOUT nursing
Specialist college services
Domiciliary care services
Extra care housing services
Shared lives
Supported living services
Ambulance services
Blood and transplant services
Remote clinical advice services
Location
 A place in which, or from which, regulated activities are provided or managed
 Each place if the regulated activities provided are managed independently
 Generally means each separate GP surgery, walk-in centre, etc is a location
 A single GP practice is one location
 Branch surgeries
 Include if associated with the main surgery the main surgery’s location
 Only if patients from the same registered list are seen or treated at all these places
 If the branch surgery treats patients from a different registered patient list to
that of the main surgery, it will need to be included in your registration as a
location in its own right
 More than one location requires one registration application with details about
all locations
Fees
 Application is free
 Annual fee for maintaining registration
 GP Provider fee rates subject to consultation
 Suggest you respond
 OOH fees
 £800 for single location
 £1,600 for 2 – 3 locations
Essential Standards
 CQCs conversion of the Regulations into patient outcomes
 Standards and outcomes are best viewed as being
interchangeable terms
 CQC has created prompts that provide further detail on
the patient outcomes
Essential Standards I
1 Respecting and involving people who use services
2 Consent to care and treatment
4 Care and welfare of people who use services
5 Meeting nutritional needs
6 Cooperating with other providers
7 Safeguarding people who use services from abuse
8 Cleanliness and infection control
9 Management of medicines
10 Safety and suitability of premises
11 Safety, availability and suitability of equipment
12 Requirements relating to workers
13 Staffing
14 Supporting workers
16 Assessing and monitoring the quality of service provision
17 Complaints
21 Records
Essential Standards II
3
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Fees
Statement of purpose
Notification of death of a person who uses services
Notification of death or unauthorised absence of a person who is detained or
liable to be detained under the Mental Health Act
Notification of other incidents
Requirements for an individual or partnership providers
Requirement where provider is a body other than a partnership
Requirements relating to registered managers
Registered person training
Financial position
Notifications – notice of absence
Standards and Registration
 Applicants make a specific declaration of compliance or non-
compliance against 16 of the standards
 These are the standards that relate most directly to the quality and safety
of the care you provide
 The remaining 12 standards relate to the routine day-to-day
management of a service
 include certain notifications you must make to the CQC once registered
 No declaration of compliance with these in an application
 Still required to meet the outcomes
Non compliance
 At registration of an existing provider
 Can be registered for 1 April 2013
 Declaration forms the basis of your legal registration with the CQC so it
is important that your declarations are true and honest
 It is highly unlikely that CQC will refuse your application just
because you declare non-compliance with any of the essential
standards
 Registration may sometimes be subject to conditions
 If declaration of non-compliance against any of the essential
standards
 Must submit an action plan of how to achieve compliance
 Action plan should be concise and succinct
Compliance
 Not necessarily straight forward
 May be achieved in more than one way
 Some very obvious
 Some by addressing the issue differently
 Take advice and consider option
 Is not achieved by having policies but by implementing
them
 Keep records of why compliance is achieved
Compliant?
 GPC guidance takes GPs through each standard where
compliance must be declared
 Full explanation of the 12 requirements
 Some examples
Inspections
 Regime not yet determined
 Likely to be a minimum of biennial
 Specific visits after concerns
 Some notice will be usually given
 Focus on outcome not policy
Possibly difficult standards
5 Meeting nutritional needs
6 Cooperating with other providers
7 Safeguarding
8 Cleanliness and infection control
10 Safety and suitability of premises
12 Requirements relating to workers
Meeting nutritional needs
 Only relevant where food and hydration are provided
 As part of the services provided
 This is not the case for most primary care providers
 No option to declare “irrelevant”
 Declaring non-compliance requires CQC to act as non
compliance implies risk to patients
 As there is no risk you should declare compliance
Cooperating with other providers
 Patients will receive safe and coordinated care, treatment and support
where more than one provider is involved, or they are moved between
services
 A practice will expect to be compliant if
 cooperate with others involved in the care, treatment, and support of a
patient when the provider responsibility is shared or transferred to one
or more services, individuals, teams, or agencies;
 share information in a confidential manner with all relevant services,
individuals, teams, or agencies to enable the care, treatment, and
support needs of patients to be met;
 work with other services, individuals, teams, or agencies to respond to
emergency situations;
 support patients to access other health and social care services they
need
Claiming compliance?
 Discuss with patients the options and arrangements for referral
 Include in correspondence all of the information that would reasonably be
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required to treat the patient safely and effectively [see guidance for a list]
When patients leave transfer the relevant information to the new provider(s) in
a timely manner so that the needs of patients can be met in an appropriate
timescale
In the case of children and patients without the capacity to give consent,
ensure that their parents/guardian/representatives are involved and informed
about referral decisions
When referring patients, ensure that patients know at least what type of
information is being transferred
Respects the right of patients to request information about them to be
transferred to another provider unless there is a good reason for not doing so
Documentation
 An emergency preparedness plan including arrangements for
sharing information and working with other providers
 Have a confidentiality protocol/information governance
protocol that refers to information disclosures to ensure that
data is transferred/received safely and securely
 A protocol for acting on correspondence and results, to
ensure that your staff are able to respond in a timely manner
to incoming information
At a visit…
 No good just having your policy document
 CQC is about demonstrating outcomes
 What do the staff and doctors actually do
 What will they say they do
 Much of visit is talking to service users and staff
Safeguarding
 Patients are protected from abuse, or the risk of abuse, and
their human rights are respected and upheld
 Compliance is anticipated if the practice
 takes action to identify and prevent abuse from happening in a
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service
responds appropriately when it suspects abuse has occurred or is
at risk of occurring
ensures that Government and local guidance is accessible to all
staff and put into practice
understands how diversity, beliefs and values of people who use
services may influence the identification, prevention and
response to safeguarding concerns
protect others from the negative effect of any behaviour by
people who use services
Claiming compliance
 Ensure staff have had safeguarding training appropriate to
their role
 Take appropriate action to protect patients if any member of
staff exploits a vulnerable adult or child
 Ensure patients can raise concerns and make complaints
related to abuse
 Have a mechanism for patients to make comments and a
publicised complaints procedure.
 Share relevant information with other providers, in
accordance with local safeguarding procedures
 Comply with the Vetting and Barring Scheme
Documentation
 A safeguarding children (child protection) policy
 A safeguarding adults policy
 A patient information leaflet about abuse
 What patients should do if they have suspicions that
another person has been abused
 What they might expect to happen under safeguarding
procedures
At a visit…
 No good just having your policy document
 CQC is about demonstrating outcomes
 What do the staff and doctors do
 What will they say they do
Safety and suitability of premises
 Patients are treated in safe accessible surroundings
that promote their wellbeing
 Premises should be safe and secure from risks
created by premises design and layout
 Premises should be managed to reduce risks
 The key to this outcome is to recognise risks and
manage them
 Where possible, make adjustments that are
reasonably practical
Claiming compliance
 Patients, staff and others know they are protected against the
risks of unsafe or unsuitable premises by:
 The design and layout of the premises being suitable for the activity
 Appropriate measures being in place to ensure the security of the premises
 The premises and any grounds being adequately maintained
 Compliance with any legal requirements relating to the premises
 Account is taken of any relevant design technical and operational
standards
 When an issue cannot be resolved seek to manage the risks
 Displaying appropriate information (e.g. alternative practices, how to access
support)
 Providing appropriate support to patients
 Adjusting how you use different parts of your premises
At a visit…
 No good just having your policy document
 CQC is about demonstrating outcomes
 Why did you claim compliance
 What do the staff and doctors do in practice
 What will they say they do
Table work I
 Registered managers
 Who should have the role in our practice
 Why
 What support is needed
 Who should manage the CQC account
 The registered manager
 Practice manager
 How do they get support
Table work II
 Each table has at least:
 One Essential Standard requiring compliance to be claimed
at application
 One other Essential Standard
 Your tasks
 Make a record of why you are/are not compliant
 Write an action plan to achieve compliance
 Consider how you would ensure the reporting standards
are met